United States Government Accountability Office

GAO Report to Congressional Requesters

NO CHILD LEFT 

BEHIND ACT 

Improved 

Accessibility to 

Education’s 

Information Could 

Help States Further 

Implement Teacher 

Qualification 

Requirements 

November 2005 

 

GAO-06-25 
 November 2005

NO CHILD LEFT BEHIND ACT 

Improved Accessibility to Education’s 

Information Could Help States Further 

Implement Teacher Qualification 

Requirements 

Highlights of GAO-06-25, a report to 

congressional requesters 

www.gao.gov/cgi-bin/getrpt?GAO-06-25.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie Shaul at 

(202) 512-6778 or shaulm@gao.gov. 

The No Child Left Behind Act 

(NCLBA) of 2001 established 

qualification requirements that

teachers of core academic subjects 

must meet by the end of the 2005-

2006 school year. Congress has

appropriated approximately $3

billion a year through the Title II, 

Part A (Title II), of NCLBA for 

teacher improvement programs 

since the law was passed. With the 

deadline approaching for all 

teachers to meet the requirements, 

GAO was asked to examine (1) the 

status of state efforts to meet

NCLBA’s teacher qualification 

requirements, (2) the use of Title II

funds in selected districts, and (3) 

how the U.S. Department of

Education (Education) monitors 

states and assists them with 

implementation of the 

requirements. To obtain this

information, GAO reviewed teacher 

qualifications data submitted to 

Education by 47 states, conducted 

site visits to 6 states selected for 

variance in factors such as teacher 

requirements and geographic

location, visited 11 school districts 

across these states identified as

high-need, and interviewed national 

experts and Education officials. 

GAO recommends that the

Secretary of Education explore 

ways to make the Web-based 

information on teacher 

qualification requirements more 

accessible to users of its Web site. 

In comments, Education officials 

agreed with our recommendation 

and reported taking actions to

address it. 

Data reported to Education by 47 states suggest that the majority of core 

academic classes were taught by teachers who met NCLBA requirements 

during the 2003-2004 school year. States have improved in their ability to 

track and report the percentage of core academic classes taught by teachers 

who met NCLBA qualification requirements, but several limitations on the 

quality and precision of state-reported data make it difficult to determine the 

exact percentage of core academic classes taught by teachers meeting the 

requirements. Five of the 6 states that we visited allowed veteran teachers to 

demonstrate subject matter competency through a state-developed 

procedure called High Objective Uniform State Standard of Evaluation 

(HOUSSE). Officials in states and districts that we visited said that teachers 

of multiple subjects, such as teachers in rural schools with a small teaching 

staff, would likely face challenges meeting the requirements by the 2005-2006 

deadline. 

The 11 school districts that we visited all used Title II funds to provide 

professional development, and most used Title II funds to reduce class size. 

Officials in the majority of these districts indicated that NCLBA had led to 

improvements in the kinds of professional development they funded with 

Title II funds. Although officials in over half of the districts indicated that 

they continued to use Title II funds to reduce class size, an activity that was 

supported under a federal program that predated NCLBA, some district 

officials told us that they had shifted funds away from class size reduction to 

initiatives designed to improve teachers’ subject matter knowledge and 

instructional skills, such as professional development. All districts that we 

visited reported considering student achievement data and targeting Title II 

funds to improve instruction in the academic subjects in which students 

were lagging behind. In the 11 districts, few efforts funded with Title II 

targeted specific groups of teachers, such as teachers in high-poverty 

schools. Title II funds constituted a small proportion of total funds that 

districts could use for teacher improvement initiatives, and all districts that 

we visited used several other funding sources to support their teacher 

programs. 

Education monitored state efforts to meet the teacher qualification 

requirements and offered multiple types of assistance to help teachers meet 

the requirements. In monitoring states, Education has found several areas of 

concern, such as states not ensuring that certain newly hired teachers met 

NCLBA’s requirements. Education’s assistance has included professional 

development for teachers and site visits to provide technical assistance to 

state officials. Education officials said that their Web site has been an 

important tool for disseminating resources about the requirements, but 

officials from most states and districts that we visited told us that they were 

unaware of some of these resources or had difficulty locating them, despite 

frequently using the Web site. 
Contents 

Letter 1

Results in Brief 3 

Background 5

States Have Made Progress in Meeting Teacher Qualification 

Requirements, but Challenges Remain 16 

Visited School Districts Most Often Used Title II Funds for 

Professional Development 27 

Education Monitored States and Offered Assistance on

Implementing the Requirements, but Some of Education’s 

Information Was Not Readily Accessible 36 

Conclusions 43

Recommendation for Executive Action 44 

Agency Comments and Our Evaluation 44 

Appendix I Activities on Which States and Districts Can Spend 

Title II, Part A, Funds 46 

Appendix II State-Reported Percentage of Core Academic Classes 

Taught by Teachers Meeting NCLBA’s Teacher 

Qualification Requirements in the 2003-2004 

School Year 48 

Appendix III Sample HOUSSE Procedures from Two States Visited 50 

Appendix IV Comments from the U.S. Department of Education 53 

Appendix V GAO Contact and Staff Acknowledgments 54 

Related GAO Products 55 

Page i GAO-06-25 Teacher Qualification Requirements
Tables 

Table 1: Major Findings from Education’s Title II Monitoring 38 

Table 2: NCLBA’s Criteria for HOUSSE Procedures 39 

Table 3: Title II, Part A, State Activities 46 

Table 4: Title II, Part A, District Activities 47 

Figures 

Figure 1: Federal Teacher Qualification Criteria 8 

Figure 2: Phase-in of Teacher Qualification Requirements 11 

Figure 3: Overview of HOUSSE Point Systems in Site Visit States 19 

Figure 4: Information on Teacher Qualifications Available through 

Education’s Web Site, as of August 2005 43 

Abbreviations 

HOUSSE High Objective Uniform State Standard of Evaluation 

IDEA Individuals with Disabilities Education Act 

LEA local education agency 

NCLBA No Child Left Behind Act

TAC Teacher Assistance Corps 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page ii GAO-06-25 Teacher Qualification Requirements
United States Government Accountability Office

Washington, DC 20548 

 

November 21, 2005 

The Honorable John A. Boehner 

Chairman 

The Honorable George Miller 

Ranking Minority Member 

Committee on Education and the Workforce 

House of Representatives 

Although research over the past 10 years has shown that teachers play a 

significant role in improving student performance, many teachers, 

especially those in high-poverty districts, lack competency in the subjects

they teach. Recognizing this, the Congress passed the No Child Left 

Behind Act of 2001 (NCLBA), which established qualification requirements 

for the nation’s approximately 3 million public school teachers, and made 

states, districts, and schools responsible for ensuring that teachers meet 

these requirements. Specifically, the act requires that teachers of core 

academic subjects such as math and science be “highly qualified” by the 

end of the 2005-2006 school year. 1

 To meet the requirements, teachers 

must (1) have at least a bachelor’s degree, (2) be certified to teach by their 

state, and (3) demonstrate subject matter competency in each core 

academic subject they teach. Under the act, teachers may demonstrate 

subject matter competency through different avenues, including a statedeveloped High Objective Uniform State Standard of Evaluation

 1

 In its October 21 letter to the states, the Department of Education (Education) indicated 

that states demonstrating a good-faith effort to meet the teacher qualification requirements

will have until the end of 2006-2007 school year for all teachers to become highly qualified. 

Education acknowledged the effects of Hurricane Katrina on the ability of some states to 

meet the teacher qualification requirements by the deadline, and noted in this and other 

correspondence that it will work with affected states and school districts to determine 

whether any flexibility will be needed with regard to implementing these requirements. As 

of October 21, Education had not granted any waivers regarding the teacher qualification 

requirements to affected states, but indicated that it may consider certain waivers or 

additional flexibility, depending on state’s needs. Education indicated in a September 21 

letter to Louisiana that it may extend the deadline for reporting on the state’s 

implementation of NCLBA provisions, including reporting on the status of teachers in

meeting the requirements, if the states determine that additional time is needed. In 

response to Mississippi’s request for a waiver of the teacher qualification requirements, 

Education noted in a September 12 letter to the state that it would continue to review this 

matter and would like more information to assess the state’s specific needs. Finally, 

Education noted in a September 21 letter to Texas that it will postpone its monitoring visit 

to assess the state’s implementation of the teacher qualification requirements, originally 

scheduled for December 2005. 

Page 1 GAO-06-25 Teacher Qualification Requirements
(HOUSSE). State HOUSSE procedures give veteran teachers—generally 

those with 1 or more years of experience—the opportunity to demonstrate 

subject matter competency through teaching experience, professional 

development, coursework, and other activities. If teachers do not meet the

requirements, school districts may be required to take certain actions, 

such as providing additional professional development.2

To help states and districts meet NCLBA’s teacher qualification 

requirements, the Congress has appropriated approximately $3 billion a 

year in grants through the Title II, Part A (Title II), of NCLBA since the law 

was passed. This amount constituted about 7 percent of all federal funds 

made available to states in 2004 for supporting education in kindergarten 

through 12th grade. Title II replaced the Eisenhower Professional 

Development and Class-Size Reduction programs, allowing states and 

districts to use funds for similar purposes, including training of teachers 

and hiring of additional teachers to reduce class size, as well as various 

other activities to help recruit, retain, and develop teachers. The 

Department of Education (Education) monitors states’ implementation of 

NCLBA and provides assistance to states to help them understand the 

teacher qualification requirements in the act and appropriate uses of Title 

II funds. 

In our prior work, we found that states and districts faced challenges in

ensuring that teachers met the requirements and also generally did not 

have data systems that could track teacher qualifications by subject in 

order to determine teachers’ status in meeting the requirements for those 

subjects.3

 In response to congressional requests, we are providing 

information on (1) the status of state efforts to meet NCLBA’s teacher 

qualification requirements, (2) the use of Title II funds in selected districts, 

and (3) how Education monitors states and assists them with

implementation of the requirements. 

To obtain this information, we used multiple data collection methods. 

First, to provide a national perspective, we reviewed teacher qualification 

 2

 In its October 21 letter to the states, Education indicated that it reserves the right to take 

appropriate action including the withholding of funds if states are not in compliance with 

the statutory teacher qualification requirements or are not making a good-faith effort to 

ensure that all teachers meet the qualification requirements. 

3

 See GAO, No Child Left Behind Act: More Information Would Help States Determine 

Which Teachers Are Highly Qualified, GAO-03-631 (Washington, D.C.: July 17, 2003). 

Page 2 GAO-06-25 Teacher Qualification Requirements
data in the consolidated performance reports that 47 states submitted to 

Education for the 2003-2004 school year, the latest year for which these 

reports were available. The remaining 3 states, the District of Columbia, 

and Puerto Rico did not provide these data to Education. We identified

several factors that affect the accuracy of these data and preclude a 

comparison of classes taught by teachers meeting the requirements across 

states. However, on the basis of our work, we determined state-reported 

percentages could be used to demonstrate how close a particular state 

was to reaching the goal of having all its teachers meet the requirements. 

The extent of the data limitations is not currently known, and Education 

has followed up with all states to obtain additional information on their 

processes for collecting these data. Second, to provide information on 

how selected states and districts are implementing the requirements and 

using Title II funds, we visited and interviewed officials in 6 states—

California, Colorado, Kansas, Maryland, Rhode Island, and Tennessee—to 

collect in-depth information on their efforts to meet teacher qualification

requirements and use of Title II funds. These states were selected for 

variance in procedures for teachers to demonstrate subject matter 

competency, reported quality of their data systems, amount of Title II 

funds received, and geographic location. At the time of our site visits, none 

of the states had been visited for monitoring purposes by Education. 

Across these states, we visited 11 of the nation’s 14,466 school districts, 

including both urban and rural districts that state officials had identified as

high-need based on their poverty level and teacher challenges they 

experienced. We also interviewed officials from Education, national 

education organizations, and teachers’ unions. In addition, we reviewed 

Title II monitoring reports completed by Education as of July 2005. Finally, 

we analyzed Education’s documents and Web site, legislation, and other 

materials related to the teacher qualification requirements and Title II 

funds. We conducted our work between November 2004 and October 2005 

in accordance with generally accepted government auditing standards. 

The data reported by 47 states to Education suggest that the majority of 

core academic classes were taught by teachers who met NCLBA 

requirements during the 2003-2004 school year. States have improved in 

their ability to track and report the percentage of core academic classes 

taught by teachers who met NCLBA qualification requirements, but several 

limitations affect the quality and precision of state-reported data, making it 

difficult to determine the exact percentage of core academic classes 

taught by teachers meeting the requirements. Five of the 6 states that we 

visited had HOUSSE procedures in place that offered multiple options for 

veteran teachers—generally those with 1 or more years of experience—to

Results in Brief 

Page 3 GAO-06-25 Teacher Qualification Requirements
demonstrate subject matter competency, such as through a combination of 

experience, academic coursework or professional development, and 

leadership or service activities. Three of these states also used other 

methods of evaluating teachers’ subject matter knowledge as part of their

HOUSSE procedures, such as observing teachers’ performance or 

assessing teachers’ contributions to student achievement. Despite the 

number of ways allowed for teachers to demonstrate subject matter 

competency, state and district officials and national association 

representatives told us that teachers providing instruction in multiple core 

academic subjects, such as teachers in rural schools with a small teaching 

staff, would likely face difficulty in meeting the requirements by the 

deadline of school year 2005-2006. 

The 11 school districts that we visited used Title II funds to provide 

professional development for teachers, particularly in core academic 

subjects. Officials in the majority of these districts also told us that 

NCLBA’s emphasis on student achievement and on strategies supported by 

research had led to improvements in the kinds of professional 

development they funded with Title II funds. Officials in 7 of the 11 

districts indicated that they continued to use Title II funds to support class 

size reduction efforts, but some district officials told us that they had

begun shifting emphasis from class size reduction to professional 

development. In identifying appropriate uses of Title II funds, most 

districts that we visited considered student achievement needs and then 

targeted programs, such as professional development, to those academic 

subjects where students were lagging behind. However, only a few of 

these efforts targeted specific groups of teachers, such as teachers in highpoverty schools. Title II funds are generally a small part of total funds 

available to the districts for teacher initiatives, and districts visited also 

used non-Title II funds to address their teachers’ needs, including other 

federal, state, and local funds. For example, one district used other federal 

funds to help teachers prepare for subject matter exams; another district 

used private foundation funds to provide financial incentives for teachers

who accepted positions in the district’s most struggling schools. 

Education monitored states’ efforts to meet the teacher qualification 

requirements through its Title II monitoring process and offered assistance 

to states and districts that included professional development for teachers,

on-site visits, and guidance. In the 20 state monitoring reports that 

Education had issued as of July 2005, it identified several areas of concern

related to states’ implementation of the teacher qualification requirements. 

For example, one frequent finding was that states did not require teachers 

of history, geography, civics/government, or economics to demonstrate 

Page 4 GAO-06-25 Teacher Qualification Requirements
subject matter competency in each subject taught, as required under 

NCLBA, but instead allowed them to demonstrate competency in the

broad subject of social studies. Education also offered a variety of 

assistance both to the nation’s approximately 3 million public school 

teachers and to state officials responsible for implementing the 

requirements. To assist teachers, Education offered professional 

development opportunities during 2004 and 2005 that were attended by 

about 4,500 teachers and distributed 255,000 “Toolkit for Teachers” 

information packets. Assistance to state officials included site visits to 

discuss NCLBA’s teacher qualification requirements and offer technical 

assistance, information on innovative state and local initiatives, and 

guidance. Education officials said that the department’s Web site has been 

an important part of their efforts to implement NCLBA’s teacher 

qualification requirements. However, officials from most states and 

districts that we visited told us that they were unaware of some of these 

resources or had difficulty locating them, even though they use 

Education’s Web site to access information on teacher requirements and 

programs. For example, officials from 4 states told us that information on 

other states’ efforts to improve teacher qualifications would be helpful, but 

they were unaware that Education offered this online. Our review of 

Education’s Web site found that resources on NCLBA’s teacher 

qualification requirements were located on several different Web pages 

that were sometimes not linked, making it challenging to find them. 

To help states address the issues of teacher quality and ensure that all 

teachers meet NCLBA’s qualification requirements, we are recommending 

that the Secretary of Education explore ways to make the Web-based 

information on teacher qualification requirements more accessible to 

users of its Web site through such activities as more prominently 

displaying the link to state teacher initiatives or enhancing the capability 

of the search function. 

The NCLBA of 2001 amended and reauthorized the Elementary and 

Secondary Education Act, the largest and most comprehensive federal 

education law. The focus of this legislation is on improving students’ 

academic performance. A growing body of research has shown that 

teacher effectiveness is a significant factor in improving students’ 

academic performance. Research has also shown that many children, 

especially those in high-poverty and high-minority schools, are assigned to 

teachers who lack knowledge of the subjects they teach. For example, a 

2004 report stated that one out of four high school courses was being 

taught by teachers without a college major, or even a minor, in the subject 

Background 

Page 5 GAO-06-25 Teacher Qualification Requirements
taught, and that students in high-poverty classrooms were more likely to 

be assigned to such teachers than students in low-poverty classrooms.4

Historically, states have been responsible for developing and 

administering their education systems, and most states have delegated the 

authority for operating schools to local governments. States and local

governments provide most of the money for public elementary and 

secondary education. Education reported that 49 percent of the revenue

for public elementary and secondary education in the 2001-2002 school 

year came from state sources, 43 percent came from local sources, and 8 

percent came from federal sources.5 As a result, state and local dollars 

fund most major expenses, such as teacher salaries, school buildings, and

transportation. Although the autonomy of districts varies, states are 

responsible for monitoring and assisting their districts that, in turn, 

monitor and assist their schools. 

The federal government has played a limited but important role in 

education. Education’s mission is to ensure equal access to education and 

promote educational excellence throughout the nation by, among other 

things, supporting state and local educational improvement efforts, 

gathering statistics and conducting research, and helping to make 

education a national priority. Education is responsible for providing 

assistance to states to help them understand the provisions or 

requirements of applicable laws and oversees and monitors how states 

implement them. With the passage of NCLBA, which requires public 

school teachers to be highly qualified in every core academic subject they 

teach, 6 the federal government for the first time established specific 

criteria for teachers. 

The act requires all teachers of core academic subjects to have a 

bachelor’s degree, state certification, and demonstrable subject matter 

 4

 “The Real Value of Teachers,” Thinking K-16, Vol. 8, Issue 1 (The Education Trust, Winter 

2004). 

5

 U.S. Department of Education, National Center for Education Statistics, The Condition of 

Education 2005. (U.S. Department of Education, Institute of Education Sciences, 2005). 

6

 Core subjects include English, reading or language arts, mathematics, science, foreign 

languages, civics and government, economics, arts, history, and geography. 

Page 6 GAO-06-25 Teacher Qualification Requirements
competency for each core subject taught.7

 Under the act, teachers may not 

have state certification requirements waived on an emergency, temporary, 

or provisional basis. According to the Education Commission of the 

States, every state required 4 years of college preparation for teacher 

certification as of 1974. However, ensuring that all teachers are certified 

and can demonstrate competency in the subject matter they teach 

presents a new challenge for many states. Allowable ways for teachers to

demonstrate subject matter competency vary depending upon a teacher’s 

experience and the grade level being taught. (See fig. 1.) For example, 

elementary teachers new to the profession must pass a state test to 

demonstrate subject knowledge and teaching skills. States have the 

flexibility to identify and approve such tests for new teachers, as well as 

establish the passing scores on the tests. Middle school and high school 

teachers have a number of options available to them for demonstration of 

subject matter competency, including a college major or a state test in the 

subject taught. In addition to the options available for new teachers, 

veteran teachers have an additional avenue for demonstrating subject 

matter competency through their state’s HOUSSE procedures.8

 7

 NCLBA requirements make an exception in the certification requirement for charter 

school teachers. The law provides that teachers in charter schools meet the certification 

requirements set forth in their state’s charter school law regarding certification or

licensure. A recent GAO survey found that officials in 13 of the 39 surveyed states reported

that their state law exempted charter school teachers from certification requirements. 

8

 We use the term “veteran teacher” to refer to teachers who are not new to the teaching

profession. Education’s August 2005 guidance says that states have the authority to define

which teachers are new and not new to the profession, as long as these definitions are 

reasonable. According to the guidance, Education believes that teachers with less than 1

year of experience should be considered new and therefore must meet subject matter 

competency requirements using the methods allowable for new teachers. 

Page 7 GAO-06-25 Teacher Qualification Requirements
Figure 1: Federal Teacher Qualification Criteria 

Elementary

NCLBA’s subject matter competency requirement

Type of

teacher

New

State testa

State testa

HOUSSE

One of the following options:

One of the following options:

State testb

Major

Coursework equivalent to major

Graduate degree

Advanced certificationc

Veteran

Secondary (middle and high school)

State testb

Major

Coursework equivalent to major

Graduate degree

Advanced certificationc

HOUSSE

Source: NCLBA Pub.L.No. 107-110, section 9101(23).

Bachelor’s

degree 

and state 

certification

are required 

for all 

teachers

a

Must be a rigorous state test assessing subject and teaching skills in reading, writing, mathematics,

and other areas of the basic elementary curriculum. 

b

Must be a rigorous state test in the academic subject taught. 

c

An example is the attainment of a National Board Certification in the subject and grade level taught. 

States can make the HOUSSE option available to veteran teachers at all

grade levels. The act sets forth some general criteria for states to use in 

developing an acceptable evaluation standard. For example, the standard 

must be developed in a way that provides objective and coherent 

information about the teacher’s attainment of core content knowledge, 

must be aligned with state academic content and student achievement 

standards, and must be uniformly applied to all teachers of the same 

subject and grade level in the state. 

In March 2004, Education announced additional flexibilities to help 

teachers who deliver instruction in multiple core academic subjects and

science teachers meet the requirements. Education announced that 

veteran teachers who provide instruction in multiple core academic 

subjects will be able to demonstrate their subject matter competency 

through a single set of procedures, such as a single, streamlined HOUSSE 

covering multiple academic subjects. Education also announced that 

teachers in eligible rural areas who teach multiple core academic subjects 

and meet the requirements in at least one of those subjects would have 

additional time to demonstrate subject matter competency in the other 

Page 8 GAO-06-25 Teacher Qualification Requirements
subjects. Further, Education allowed states to rely on their own 

certification requirements for science to determine specific science areas

in which teachers will be required to demonstrate subject matter 

competency. For example, if a state certified teachers in the general field

of science, then a teacher may demonstrate subject matter competency in

the general science area instead of each separate science subject, such as 

physics or biology. 

According to Education’s August 2005 nonregulatory guidance, the NCLBA 

teacher qualification requirements apply to special education teachers 

who provide instruction in core academic subjects, such as teachers in 

self-contained classrooms.9

 These teachers may demonstrate subject 

matter competency by using any of the options allowed to other teachers 

under NCLBA. 

Qualification requirements for special education teachers were modified 

in the December 2004 reauthorization of the Individuals with Disabilities 

Education Act (IDEA).10 The reauthorized IDEA allowed some special 

education teachers additional flexibility in terms of meeting subject matter 

competency requirements. First, new special education teachers at the 

elementary level who are teaching exclusively children with significant 

cognitive disabilities may use the state HOUSSE procedures to 

demonstrate subject matter competency, an option otherwise reserved 

under NCLBA to veteran teachers.11 Second, new special education 

teachers who teach multiple core academic subjects exclusively to special

education students and already meet the requirements in mathematics, 

language arts, or science, have 2 years after hiring to demonstrate subject 

matter competency in the other subjects taught. Teachers in this second 

category may also do this through the HOUSSE process, including a single

 9

 A self-contained classroom is one in which the students stay with their teacher all day and 

for all academic subjects. In these classrooms, the special education teacher is responsible 

for providing instruction in more than one core academic subject and thus would need to

demonstrate subject matter competency in each of the subjects taught. 

10 IDEA is the primary federal law that addresses the educational needs of students with 

disabilities. Among other provisions, the law mandates that a free appropriate public 

education be made available to all eligible children with disabilities and requires an 

individualized education program for each student. 

11 Under IDEA, states can determine the level of instruction provided by middle and high

school teachers who teach students with significant cognitive disabilities. If the level of 

instruction that is being provided is equivalent to the level of instruction at the elementary 

level, the requirements for elementary teachers apply. 

Page 9 GAO-06-25 Teacher Qualification Requirements
evaluation covering all academic subjects taught. Finally, veteran special 

education teachers who teach multiple core academic subjects exclusively 

to special education students have the option of demonstrating subject 

matter competency through a multisubject HOUSSE, consolidated to 

assess teachers’ subject matter knowledge in multiple subjects through a 

single process. 

The deadline for teachers to meet the requirements depends on the type of 

school in which they work. Starting with the first day of the 2002-2003 

school year, all new teachers hired into school programs supported with 

Title I funds must demonstrate compliance with the requirements 

immediately upon hire.12 Most other teachers have until the end of 2005-

2006 school year to meet the requirements in the law. The current 

timelines for teachers to meet the requirements are shown in figure 2.13

 12 Title I, Part A, of the Elementary and Secondary Education Act, allocated more than $12

billion in fiscal year 2004 to serve disadvantaged students in approximately 90 percent of 

the nation’s school districts.

13 In October 2005, Education announced that states showing sufficient effort in 

implementing the teacher qualification requirements but still falling short of having all their 

teachers meet them by the end of 2005-2006 school year, will be able to negotiate with 

Education a plan for achieving that goal by the end of 2006-2007 school year. 

Page 10 GAO-06-25 Teacher Qualification Requirements
Figure 2: Phase-in of Teacher Qualification Requirements 

Deadlines

for meeting

requirements

Categories

of teachers

Immediately

upon hiring

Title I 

teachers 

hired on or 

after first 

day of 

2002-2003 

school year

Most other 

teachers 

of core 

academic 

subjects

End of 

2005-2006

school year

End of 

2006-2007

school year

Current rural 

teachers who 

teach two or 

more core 

academic 

subjects and 

who had 

already met the 

requirements 

in at least 

one subject

Newly hired 

rural teachers 

who teach two 

or more core 

academic 

subjects and 

who had 

already met the 

requirements 

in at least 

one subject

Newly hired 

special 

education 

teachers

who teach 

two or more 

core academic 

subjects and 

who had 

already met the 

requirements 

in at least 

one subject

3 years

after hiring

2 years

after hiring

Source: NCLBA Pub.L.No. 107-110 section 1119(a), Education’s August 2005 Title II, Part A, Non-Regulatory Guidance, and IDEA 

Pub. L. No. 108-446, section 602(10).

Prior GAO work found that states and districts were experiencing 

challenges implementing NCLBA’s teacher qualification requirements. 

Among the most commonly cited challenges were difficulties with teacher 

recruitment and retention resulting from factors such as low teacher pay,

lack of adequate professional development opportunities, and difficulty 

developing and implementing state data systems for tracking teacher 

qualifications.

14 We found that challenges were especially acute in small, 

isolated rural districts where teachers often had to teach multiple subjects

across different grade levels.15 Furthermore, although we found that all 

states required that special education teachers have a bachelor’s degree 

and be certified to teach—two of the three NCLBA teacher qualification 

requirements—many states did not require them to demonstrate subject 

matter competency. As the result, we concluded that state-certified special 

education teachers who were assigned to teach core academic subjects 

 14 See GAO-03-631. 

15 See GAO, No Child Left Behind Act: Additional Assistance and Research on Effective

Strategies Would Help Small Rural Districts, GAO-04-909 (Washington, D.C.: Sept. 23, 

2004). 

Page 11 GAO-06-25 Teacher Qualification Requirements
might not be positioned to meet NCLBA requirements.16 In the aftermath of 

Hurricane Katrina, states and districts faced with large numbers of 

displaced teachers and students may have additional challenges tracking 

teacher qualification status and ensuring that all teachers meet the 

requirements by the deadline. Education indicated that it will work with 

affected states and school districts to determine what flexibility will be 

needed with regard to implementing the teacher qualification 

requirements. 

Federal funding for teacher initiatives was provided prior to NCLBA, but 

the act increased the level of funding to help states and districts 

implement the teacher qualification requirements. Prior to NCLBA, the 

Eisenhower Professional Development and Class-Size Reduction programs 

provided funds to the states primarily for professional development in 

mathematics and science and efforts to reduce class size for students in 

kindergarten through third grade. Title II replaced these two programs, 

providing states and districts with approximately $2.85 billion for fiscal 

year 2002 to help them implement various initiatives for raising teacher 

and principal qualifications—$740 million more than provided in fiscal 

year 2001 under the previous two programs. In fiscal year 2004, Title II 

provided $2.93 billion to states and districts through Improving Teacher 

Quality State Grants. 

The formula currently used to allocate funds to states and districts is 

similar to the formula used under the Eisenhower Professional 

Development and the Class-Size Reduction programs and takes into 

account poverty and student enrollment. Specifically, the amount of Title 

II funds that each state or district receives is based on its 2001 allocation

under the two previous programs, the number of children aged 5 to 17, and

the number of those children residing in families with incomes below the 

poverty line.

17 After reserving up to 1 percent of the funds for 

administrative purposes, states allocate 95 percent of the remaining funds 

to the districts. They retain 2.5 percent to support state-level teacher 

initiatives and allocate the remaining 2.5 percent to the state agency for 

higher education to support partnerships between higher education 

 16 See GAO, Special Education: Additional Assistance and Better Coordination Needed 

among Education Offices to Help States Meet NCLBA Teacher Requirements, GAO-04-659 

(Washington, D.C.: July 15, 2004). 

17 For 2004, the poverty threshold was $19,484 annually for a family of four. 

Page 12 GAO-06-25 Teacher Qualification Requirements
institutions and high-need districts that work together to provide 

professional development to teachers. 

While there is no formula in NCLBA for districts to allocate funds to 

specific schools, the act requires states to ensure that districts target funds

to those schools with the highest number of teachers who are not highly

qualified, the largest class sizes, or that have been identified to be in need 

of improvement. In addition, districts applying for Title II funds from their 

states are required to conduct a districtwide needs assessment to identify

their teacher quality needs. Among other things, the needs assessment 

should identify those needs that must be addressed if the district is to have 

all its teachers meeting NCLBA’s requirements by the deadline. The needs 

assessment should take into account activities needed to provide teachers 

with the means for helping students meet challenging state and local 

academic achievement standards. Districts must involve teachers in the 

development of their needs assessment and may consider a variety of 

factors, such as teacher and student achievement data and projections of 

professional development necessary to help all teachers meet NCLBA’s 

qualification requirements. 

Under Title II, acceptable uses of funds include teacher certification 

activities, professional development in a variety of core academic subjects, 

and recruitment and retention initiatives, including hiring teachers in 

order to reduce class size. (See app. I for state and district authorized 

activities.) Some of these activities, such as recruitment of new teachers 

and professional development in math and science, could be funded under 

the Eisenhower Professional Development and Class-Size Reduction 

programs as well. However, states and districts have more flexibility in 

how to spend Title II funds than was previously possible. For example, 

while under the Class-Size Reduction Program, funds could be spent on 

financial incentives and mentoring programs for new teachers only, Title II 

funds can be used for existing teachers as well, if the district identifies a 

need. While the Eisenhower program focused primarily on professional 

development in math and science, allowable activities under Title II may 

include any subject. Under NCLBA, professional development is 

considered to be an important component of the overall strategy to 

Page 13 GAO-06-25 Teacher Qualification Requirements
improve the quality of teaching and raise student achievement, and the law 

provides the definition of professional development.18

In addition to using Title II funds for the purposes of raising teacher 

qualifications, districts can also transfer these funds to most other NCLBA 

programs to meet their educational priorities. Specifically, districts are 

allowed to transfer up to 50 percent of the funds allocated to them under 

most major NCLBA programs, including Title II, into other programs under 

NCLBA.19 Thus, for example, districts may transfer a portion of their Title 

II funds into Title I for initiatives designed to improve student 

achievement. 

Regardless of whether or not districts transfer funds under the 

transferability option, they can spend non-Title II funds, such as Title I 

funds, to support teacher initiatives. Under NCLBA, districts are required

to spend at least 5 percent of their Title I funds on helping teachers meet 

the qualification requirements. Additionally, schools in the district that do 

not meet their student proficiency goals for 2 or more consecutive years 

are required to spend at least 10 percent of their Title I funds to provide 

the school’s teachers and principals with high-quality professional 

development. 

States must prepare and publicly disseminate an Annual State Report Card 

with information on the professional qualifications of teachers in the state, 

the percentage of such teachers on emergency or provisional credentials, 

and the percentage of core academic classes being taught by teachers who 

do not meet NCLBA’s teacher qualification requirements. Further, Title I of

 18 NCLBA defined professional development in Title IX of the act. Among other things, the

definition emphasizes the type of professional development that increases teachers’ 

academic knowledge, gives teachers the knowledge and skills to provide students with the 

opportunity to meet challenging state content and student achievement standards, is 

sustained and intensive rather than short-term, and increases teachers’ understanding of 

effective instructional strategies that are based on the principles of scientifically based 

research. 

19 Under Title VI of NCLBA, a district meeting its annual student proficiency goals may 

transfer up to 50 percent of the funds allocated under any of the following programs: Title 

II, Part A (Improving Teacher Quality State Grants); Title II, Part D (Educational 

Technology State Grants); Part A of Title IV (Safe and Drug-Free Schools and 

Communities); and Part A of Title V (State Grants for Innovative Programs). Districts not 

meeting their student proficiency goals for at least 2 years are identified for improvement

and cannot transfer more than 30 percent of their funds under any given program. Districts

not meeting their goals for at least 4 years are identified for corrective action and are 

prohibited from transferring funds under this option.

Page 14 GAO-06-25 Teacher Qualification Requirements
NCLBA requires districts and schools to inform parents about the 

qualifications of their children’s teachers. Districts are required to notify 

parents of all students attending Title I schools that they have the right to 

request information about the qualifications of their child’s teacher. 

Schools must further notify parents if their child has been taught by a 

teacher who did not met NCLBA’s teacher qualification requirements for 4 

or more consecutive weeks. 

The accountability provisions under Title I of NCLBA require every state 

and district receiving Title I funds to develop and submit a plan for how it 

intends to meet the teacher qualification requirements, along with other 

provisions of the act such as adopting challenging academic content and

student achievement standards. The state plan must establish each 

district’s and school’s annual measurable objectives for increasing the 

number of teachers meeting qualification requirements and receiving highquality professional development with the goal of ensuring that all 

teachers meet the requirements by the end of the 2005-2006 school year. In 

addition, beginning with the 2002-2003 school year, districts receiving Title 

I funds are required to annually report to the state on their progress 

toward state-set objectives, and all states are required to submit an annual 

report to Education detailing state progress in meeting the annual 

measurable objectives regarding teacher qualification requirements. Under 

NCLBA, school districts that do not ensure that their teachers meet the 

qualification requirements must implement certain actions, such as 

additional professional development. However, their overall funding levels 

from Education are not affected.20 If states do not meet the requirements 

for reporting on the qualifications of their teachers, the Secretary of 

Education has the authority under NCLBA to withhold state administrative 

funds. 

 20 Under Section 2141 of NCLBA, if the district falls short of its annual measurable 

objectives for ensuring that teachers meet qualification requirements for 2 consecutive 

years, it has to develop an improvement plan. During the development of the improvement

plan, the state must provide technical assistance to the district and to any schools served 

by the district that would enable it to meet its teacher qualification objectives. If the district 

continues to fall short of its annual measurable objectives and is also failing to meet its 

annual student proficiency goals for 3 consecutive years, the state has to enter into an

agreement with the district. Under that agreement, the state works with the district to 

develop professional development strategies for teachers and principals to help the district 

meet its teacher qualification objectives, and in most cases the district cannot use Title I 

funds for hiring new paraprofessionals. 

Page 15 GAO-06-25 Teacher Qualification Requirements
Education monitors states’ progress in implementing the requirements 

under both Title I and Title II of the act, as well as provides assistance to 

them. Beginning with the 2002-2003 school year, Title I of the act requires

Education to publicly report the annual progress of states, districts, and 

schools in meeting the measurable objectives for ensuring that all teachers 

meet the qualification requirements by the deadline. 

The available data suggest that the majority of core academic courses 

were taught by qualified teachers in 2003-2004. States have made progress

in tracking and reporting teacher qualification data, but challenges remain 

in reporting precise results. States offered multiple options for veteran 

teachers to demonstrate subject matter competency as part of their 

HOUSSE procedures, but the rigor of these procedures varied across the 

states that we visited. Selected state and district officials told us that 

certain groups of teachers would likely face challenges meeting the 

requirements by the 2005-2006 deadline. 

The data reported by 47 states suggest that the majority of core academic 

classes were taught by teachers who met NCLBA requirements during the 

2003-2004 school year.21 Most of these states reported that nearly all of 

their core academic classes were being taught by teachers who met the 

requirements. However, data for most states appear to show that core 

academic classes in low-poverty schools were more likely to be taught by

teachers who met the requirements than classes in high-poverty schools. 22

The data also suggest that a higher percentage of elementary school 

classes were taught by teachers who met the requirements than secondary 

school classes. State-reported percentages for each of the 47 states are 

shown in appendix II.23 Data limitations preclude a comparison among 

states but, on the basis of our work, we determined state-reported 

States Have Made 

Progress in Meeting 

Teacher Qualification 

Requirements, but 

Challenges Remain 

Most States Reported That 

the Majority of Teachers 

Are Qualified, but Some 

Data Issues Remain 

 21 These states include approximately 97 percent of all public school students in the

country. 

22 High-poverty and low-poverty schools are respectively those in the top and bottom

quartiles of poverty in the state; most states based this on the percentage of students 

eligible for free or reduced lunch in the school. 

23 Education has followed up with four of the five entities that did not provide data. 

Officials indicated that changing definitions and challenges with data systems were among 

the reasons for not providing data. References to Education’s efforts to collect and assess 

teacher qualifications data from the states includes the work completed by Education’s 

data quality contractor. 

Page 16 GAO-06-25 Teacher Qualification Requirements
percentages could be used to demonstrate how close a particular state 

was to reaching the goal of having all its teachers meet the requirements. 

States have improved in their ability to track and report the percentage of

core academic classes taught by teachers who met NCLBA qualifications. 

Reports from 2002 and 2003 from national education organizations, such 

as the Education Commission of the States, showed that few states were 

able to track and report these data. Similarly, in our 2003 report on the 

NCLBA teacher qualification provisions, officials in 7 of the 8 states we 

visited told us they did not have data systems capable of tracking teacher

qualifications for each core subject.24 But by 2005, 47 states reported 

teacher qualification data to Education for the 2003-2004 school year. 

Officials in the 6 states that we visited told us that they had improved their 

data systems, either by creating a new system or by redesigning their 

existing system to collect information required under NCLBA. For 

example, several states merged their state-level teacher qualification 

systems with their district-level class assignment systems to enable them 

to determine whether classes were being taught by teachers who met the 

requirements. Education officials also told us the 2003-2004 data had 

considerably improved from earlier years and that next year’s data will 

accurately reflect the status of state efforts to implement the teacher 

qualification requirements. 

Despite this progress, several issues limit the quality and precision of 

state-reported data and make it difficult to determine the exact percentage 

of core academic classes taught by teachers meeting NCLBA qualification 

requirements. First, district officials in 3 of the 6 states that we visited told

us that they had excluded classes taught by special education teachers 

from their calculations;25 state officials in all 6 site visit states said these 

teachers faced particular challenges in meeting the requirements. Second, 

states relied on the data districts provided, but state officials generally

noted that data collection processes varied by district, and that the quality 

of the data could vary as well. For example, two districts that we visited in

1 state reported data that were based on an incorrect assumption about 

which teachers met the requirements,26 and therefore included some 

 24 As part of that study, GAO visited California, Connecticut, Illinois, Iowa, Maryland, North

Carolina, Delaware, and Wyoming. See GAO-03-631. 

25 Special education teachers must be included if they teach core academic subjects. 

26 District officials in this state told us that teachers with emergency certification and a plan 

to meet the requirements counted as meeting the requirements. 

Page 17 GAO-06-25 Teacher Qualification Requirements
teachers as meeting the requirements when they had not. Education also 

identified data problems in 13 of the 20 states for which it issued 

monitoring reports by July 2005.27 The impact and magnitude of these 

problems on state reports is unclear; state-reported data may under- or 

overstate the percentage of classes taught by teachers who met the 

requirements, depending on the nature of the data problem. Education has 

contracted with a research organization to follow up with states to identify 

any data issues that may have affected state-reported data, such as states 

excluding certain teachers subject to NCLBA’s qualification requirements 

from their calculations.28

States Offered Multiple 

Options for Veteran 

Teachers to Meet the 

Requirements 

Five of the 6 site visit states had HOUSSE procedures in place for veteran 

teachers—those generally with 1 or more years of experience—to 

demonstrate subject matter competency, and the procedures included 

many different options for teachers to use as part of HOUSSE. The 

HOUSSE procedures in these states included the use of a point system that 

allowed veteran teachers to demonstrate subject matter competency by 

earning points in categories of experience, academic coursework or 

professional development, and leadership or service activities, as well as 

for evidence of publications, presentations, or awards. Colorado officials 

said they did not have a HOUSSE but allowed teachers to demonstrate 

subject matter competency through options typically included in other 

states’ HOUSSE procedures, such as a combination of college coursework 

and professional development options.29 Figure 3 presents an overview of 

HOUSSE point systems from the 5 states we visited that had them in place. 

(App. III shows HOUSSE point systems from 2 site visit states.) 

 27 These states did not overlap with our site visit states. Education’s findings are discussed 

in a subsequent section of this report. 

28 Education’s contractor plans to issue a report on its findings regarding state teacher 

qualifications data in fall 2005. 

29 Colorado allowed teachers to demonstrate subject matter competency through 

accumulation of 24 college or professional development credits. Up to one-fourth of these 

credit hours could be accumulated through travel relevant to the subject area taught, such

as travel to Greece for a history teacher. Officials there indicated that to count travel 

toward demonstration of subject matter competency, a teacher would need to explain what 

was learned as the result of this travel and how this knowledge would contribute to student

performance, as well as demonstrate how the travel enhanced his or her content 

knowledge. The responsibility for ensuring the relevance of travel is with the districts, and 

state officials did not know how often this option was actually used. 

Page 18 GAO-06-25 Teacher Qualification Requirements
Figure 3: Overview of HOUSSE Point Systems in Site Visit States 

California

California: 50 college coursework + 50 experience = 100

Kansas: 48 college coursework + 27 experience + 25 awards = 100

Maryland: 40 college coursework + 50 experience + 10 professional development = 100

Rhode Island: 51 college coursework + 24 experience + 25 leadership = 100

Tennesee: 40 experience + 30 professional development + 30 evaluation = 100

Kansas

0-100 0-100 0-100

0-55 0-55 0-30

0-50 0-100

45-100 0-45

Marylandb 30-100 0-10 c 0-10d 0-50

Tennessee 0-40 0-30 0-30 0-40 f 0-52e

Rhode

Island 0-93 0- 0-95 95 0-20

0-20

0-24

Source: GAO analysis of state HOUSSE plans; graphics in part by Art Explosion.

Range of points that can be earned out of 100 needed

College

courseworka Professional

Experience development

Leadership/

activities/

service

Awards/

presentations/

publications

Evaluations/

observations

of teachers

Examples of how teachers can earn 100 points

a

Kansas and Maryland required teachers to earn a minimum number of points in this category. 

b

The maximum points listed are for regular education teachers. Special education teachers may have

different maximums. 

c

Maryland required elementary teachers to earn a minimum of 40 points in this category and middle 

and high school teachers a minimum of 30 points. 

d

Maryland combined leadership, activities, service, awards, presentations and publications into a 

single category with a maximum of 10 points. 

e

Tennessee allowed teachers to earn up to 40 points for classroom teaching experience and up to an

additional 12 points for teaching content courses at a postsecondary institution. 

f

Tennessee recently revised its evaluation system to emphasize assessment of teachers' subject

matter knowledge. This updated evaluation system places greater emphasis on the content taught

and is performed by evaluators trained in the new evaluation format. Teachers evaluated under the 

new system can use that as a stand-alone option for meeting all the subject matter competency 

requirements under the state's HOUSSE. Teachers evaluated under the old system can earn up to 30 

points through the state's point system—up to 20 of those points can be earned for positive 

evaluations, and up to 10 points are given to teachers who attained an advanced level of 

performance under the Tennessee Career Ladder Evaluation System, which had been in existence 

between 1985 and 1997. Although teachers can continue using the former versions of state 

evaluations to earn points toward demonstration of subject matter competency, officials indicated 

that the new evaluation system is now used statewide to assess the performance of all teachers. 

Page 19 GAO-06-25 Teacher Qualification Requirements
In addition to the categories above, the point systems in two states that we 

visited also included the option for teachers to demonstrate subject matter 

competency through advanced certification. Teachers in Maryland and 

Tennessee could earn all of the required points by achieving National 

Board Certification.30

In addition to the point system, the HOUSSE procedures in some site visit 

states offered alternatives for demonstrating subject matter competency. 

For example, teachers in Tennessee could demonstrate subject matter 

competency through multiple observations of their performance 

completed by trained evaluators or the data showing their effect on 

student achievement. Teachers in California who were unable to obtain 

the required number of points through the point system could use 

evidence of positive evaluations of their performance in the classroom or 

prepare a portfolio of their work.31

Our review of HOUSSE procedures in states that we visited, particularly 

the analysis of the points they allowed teachers to count for different 

activities, showed that they varied in the weight given to these activities. 

The extent to which certain activities reflect teachers’ subject matter 

knowledge may affect the rigor of these procedures.32 For example, as 

shown in figure 3, Rhode Island allowed experience to count for about 

one-fourth of the 100 points required for demonstrating subject matter 

competency, but the other 4 states with HOUSSE procedures allowed 

experience to count for about one-half of the points to be earned. Officials 

in Colorado indicated that they had chosen not to count experience 

toward teachers’ demonstration of subject matter competency because 

they did not believe that experience would necessarily translate into 

improved subject knowledge. However, Colorado permitted relevant travel 

to count toward demonstration of subject matter competency, whereas the 

other states did not explicitly include travel in their HOUSSE.

 30 The National Board for Professional Teaching Standards offers National Board 

Certification in subject areas such as English language arts and mathematics, requiring

teachers to create a portfolio demonstrating their work in the subject area and exercises to 

demonstrate their subject matter knowledge. For more information, please see 

http://www.nbpts.org/. 

31 Officials in California explained that their teacher preparation program included subjectspecific coursework, and they expected that their veteran teachers would count points for

college coursework and experience before counting points for other activities on the

state’s HOUSSE. 

32 Education had not yet monitored these states at the time of our site visits. 

Page 20 GAO-06-25 Teacher Qualification Requirements
Some site visit states also set a minimum number of points to be earned in 

certain categories, while other states did not require teachers to earn 

points from those categories. Specifically, Kansas and Maryland required 

teachers to earn at least a portion of the total number of points they 

needed to demonstrate subject matter competency through college 

coursework, while other states did not require a minimum number of 

points in that category. States also differed in the number of categories in 

which teachers had to earn points. For example, teachers in Rhode Island 

were required to earn points from at least three different categories, such 

as college-level coursework and professional development in the content 

area. In contrast, teachers in Maryland could earn all points necessary for 

demonstration of subject matter competency from a single category. 

California, Kansas, Rhode Island, and Tennessee also set a requirement 

that some activities had been completed within a recent period of time.33

For example, Kansas required professional development and service 

activities to have taken place within the last 6 years to earn points toward 

demonstrating subject matter competency under HOUSSE. 

Some of the options that site visit states permitted as part of their 

HOUSSE procedures relied on improved student performance or 

observations of teachers’ classroom performance. Tennessee allowed 

teachers to demonstrate subject matter competency by using data that

show their actual contribution to students’ achievement in that subject.34

To use this option for the purposes of demonstrating subject matter 

competency, teachers must demonstrate that the most recent 3-year 

average gain in the achievement of their students is not detectably 

different from or is better than the average gain for all students in the 

state. At the same time, Tennessee and California both counted positive 

evaluations of teachers’ classroom performance as evidence that could be

counted toward subject matter competency. Although both states based 

these evaluations on uniform performance standards established by the 

state, officials in these states told us that they did not oversee the 

implementation of these evaluations. As a result, we determined that they

could not effectively ensure the quality of evaluations. While we did not 

 33 Officials in California noted that the recency requirement applies to professional 

development activities accepted under the state’s HOUSSE. Specifically, teachers can earn 

points only for those professional development activities that had been completed after the

adoption of the state’s professional development standards in 1997. 

34 Such data are available for teachers through the Tennessee Value-Added Assessment 

System. 

Page 21 GAO-06-25 Teacher Qualification Requirements
conduct an in-depth review of how the evaluations of teachers’ 

performance were carried out, we identified two areas of concern for 

using this method as an objective state standard. First, the number and 

duration of the evaluation sessions may not provide enough information to 

determine subject matter competency. Second, these evaluations may be 

conducted by personnel who are also responsible for hiring and retaining 

teachers in the district, and thus these evaluators may not be objective. In

one small rural district that we visited, the assistant superintendent 

responsible for evaluating the teachers’ subject matter competency told us 

that the evaluation process was subjective. 

Finally, while most states that we visited tried to ensure that activities 

accepted as part of their HOUSSE procedures were connected to the 

subject area that the teacher taught, Maryland’s HOUSSE procedure 

awarded points for activities not directly related to the subject matter, 

such as professional development on instructional strategies and 

principles. Officials there indicated that the majority of points had to be 

earned from activities specific to the subject matter, and that the state’s 

HOUSSE procedure sought to recognize both subject matter knowledge 

and the teachers’ general teaching expertise. 

Some educational experts have noted that the rigor of HOUSSE 

procedures varied across states and expressed concerns that states whose 

procedures offered less rigorous options may not adequately assess 

teachers’ subject matter knowledge. The experts we interviewed told us 

that teachers who are not required to engage in activities directly related

to accumulating subject matter knowledge, such as completing college 

coursework in a subject, may not increase their knowledge of the subject 

taught. In addition, the experts commented that if experience is heavily

emphasized, teachers may not get the subject matter knowledge they need

to be effective in the classroom. States with less rigorous procedures may 

not bring about improvements in teachers’ content knowledge or student 

performance. Officials from Education confirmed that the rigor of 

HOUSSE procedures varied across states, as is permitted under NCLBA. 

Selected States and 

Districts Faced 

Implementation 

Challenges 

Although numerous ways exist for veteran teachers to demonstrate 

subject matter competency, officials in site visit states and districts and 

national association representatives told us that some teachers providing 

instruction in multiple core academic subjects, such as special education

teachers and teachers in rural areas and specialized school settings, may 

not meet the requirements by the deadline. Officials in the states that we 

visited noted that special education teachers would have the greatest 

Page 22 GAO-06-25 Teacher Qualification Requirements
difficulty in meeting the requirements by the deadline, because they were

originally certified in special education rather than in a specific academic

content area. In addition, special education teachers frequently provide 

instruction in multiple core academic subjects at the secondary level,

creating challenges in meeting the requirements for each subject. Officials

also noted that teachers in rural districts may face similar challenges. For 

example, an official in one state described a rural district landlocked by 

mountains where three high school teachers were responsible for teaching 

all classes across all subjects and grades at the high school level, and 

therefore had to meet the requirements for each subject. Although under 

IDEA and Education’s guidance certain special education and rural 

teachers who already meet the requirements in one core academic subject

have additional time to meet the requirements for the other subjects, 

officials were still concerned about whether these teachers will be able to 

meet the requirements for all of the subjects. Officials also reported 

challenges for middle school teachers who frequently provide instruction 

in multiple core academic subjects,35 as well as teachers in specialized 

school settings, such as schools for students dismissed from their regular 

schools as a result of behavioral problems. Officials from two districts in 

one state that we visited told us that they had a large number of these 

specialized schools, and officials there indicated that teachers often had to

teach multiple subjects to the same group of students, making it difficult 

for them because they had to meet the subject matter requirements in each 

subject taught. Education allowed states to streamline HOUSSE 

procedures by developing a method for veteran teachers of multiple core 

academic subjects to demonstrate subject matter competency in all those

subjects through a single procedure. One of the states that we visited 

offered a streamlined HOUSSE procedure for its teachers of multiple core 

academic subjects. However, officials in the other states that we visited 

did not have a single HOUSSE procedure for teachers of multiple subjects, 

and some of them indicated that they would like more information on how 

to develop one. 

Officials in states and districts that we visited also told us that schools will 

continue to have difficulty recruiting math and science teachers who meet 

 35 According to the Department of Education, states have the flexibility to determine 

whether middle school teachers—such as sixth grade teachers in some districts—will have 

to meet the requirements for elementary or secondary teachers, depending on the degree of

rigor and technicality of the subject matter that the teacher will need to know in relation to

the state’s content standards and academic achievement standards for the subjects that 

will be taught. 

Page 23 GAO-06-25 Teacher Qualification Requirements
the requirements. Schools had difficulty recruiting these secondary 

teachers even before NCLBA. These recruitment shortfalls will likely 

continue after the 2005-2006 deadline passes, in part because thereafter all 

newly hired teachers of core academic subjects, not just those in Title I 

schools, will have to demonstrate their subject matter competency before

entering the classroom. Some state and district officials told us that they

were unable to restrict hiring to teachers who met the requirements 

because there were not enough candidates who had met the requirements 

to fill all of the open positions. One state is altering its emergency 

certificate to incorporate a time limit; this certificate will allow teachers to 

provide instruction for up to 2 years before they have to fully meet the 

subject matter competency requirements.36 While state officials 

responsible for teacher licensing in the state acknowledged that the new 

certificate does not meet the requirements of NCLBA, they indicated that 

school districts might not be able to fill all their open positions with 

teachers who meet the requirements. 

We also found that 8 of the 11 districts either did not notify parents when 

their children were assigned to teachers who did not meet the 

requirements, as required under the act, or did not make the notification 

entirely clear to the parents. Five districts in the states that we visited did 

not send the letters to the parents, with some district officials stating that 

they did not know that the letters had to be sent. Officials in one state 

instructed districts not to send the letters until the 2005-2006 deadline had 

passed. Three districts in another state sent letters to the parents, but 

these letters did not explicitly indicate that the teacher did not meet the 

requirements of the law. For example, one district’s letter said that the 

teacher “is a dedicated professional who will always work in the best 

interest of your child” and “holds a probationary certificate” without 

 36 The new certificate will allow teachers with significant subject matter competency 

coursework to teach for up to 2 years as long as they demonstrate progress toward meeting

the subject matter requirements. After meeting the subject matter requirements, they can 

move into one of the state’s alternative certification programs to obtain a teaching 

certificate. Under NCLBA, teachers in alternative certification programs are considered to

have met the requirements as long as they receive high-quality professional development

and intensive supervision, assume the functions of a teacher for no more than 3 years, and 

demonstrate satisfactory progress toward obtaining state certification. 

Page 24 GAO-06-25 Teacher Qualification Requirements
explaining to the parents that probationary certificates do not meet 

NCLBA’s requirements.37

Additionally, some officials did not know about other aspects of the 

requirements, such as actions required for teachers not meeting the 

requirements and to whom the requirements applied. For example, 

officials in two states told us that they did not know what actions districts 

or schools should take against teachers who did not meet the 

requirements by the deadline. Officials in one district had fired teachers 

because they did not meet the requirements. Other districts generally had

not fired teachers who did not meet the requirements but wanted to know 

whether they should. There are no actions specified in the NCLBA with 

respect to teachers’ conditions of employment for those who do not meet 

the requirements by the deadline. In addition, officials in one district did

not know until our visit that all teachers of core academic subjects—not 

just those in Title I schools—would have to meet the requirements by the 

end of 2005-2006 school year. 

Education acknowledged the challenges that states may face in ensuring 

that all teachers meet the requirements by the end of 2005-2006 school

year. On October 21, 2005, Education announced that states may have until 

the end of the 2006-2007 school year to ensure that all their teachers meet 

the requirements if they can demonstrate that they are making good-faith 

effort toward that goal. As evidence of good-faith efforts, states will need 

to meet the following four conditions: (1) show that the state’s

requirements for teachers to demonstrate that they are highly qualified are 

consistent with the law, (2) meet the requirements for parental notification 

and public reporting, (3) provide complete and accurate teacher 

qualification data to Education in January 2006 for the 2004-2005 school 

year, and (4) take action to ensure that poor and minority students are not 

taught by teachers who do not meet the requirements at a higher rate than

other students. The letter also stated that no federal funds will be withheld 

from states if they are unable to ensure that all their teachers meet the 

requirements by the end of 2005-2006 school year, as long as these states 

are implementing the law and making a good-faith effort to reach that goal. 

 37 Education monitors state and district efforts on this requirement through its Title I 

monitoring. NCLBA does not make any provisions for penalties for districts failing to make

this notification. 

Page 25 GAO-06-25 Teacher Qualification Requirements
Despite the challenges experienced, state officials reported progress in 

better positioning themselves to meet NCLBA requirements. Although our 

2003 report showed that states we visited generally did not have data 

systems capable of tracking teacher qualifications for each core subject 

teachers taught,38 officials told us that they had improved their data 

systems since then. All of the states that we visited had either created a 

new data system or redesigned their existing data systems to collect 

information required under NCLBA. For example, several states merged 

their state-level teacher qualification systems with their district-level class

assignment systems to enable states to determine whether classes were 

being taught by teachers who met the requirements. Another state 

redesigned its data system so that it would capture teachers’ status in 

meeting the requirements. 

In addition to improving data systems, state officials also reported taking 

steps to help more teachers meet the requirements. For example, one of 

the states developed HOUSSE procedures that could be used to 

demonstrate subject matter competency across multiple subjects. Under 

those HOUSSE procedures, the same allowable activities, such as 

professional development and leadership positions, could be counted for 

more than one subject. Most states that we visited made some changes in

certification requirements or professional development standards to make 

them more consistent with the requirements of NCLBA. For example, two 

states created a separate certificate for middle school teachers that 

incorporated subject matter competency requirements—a change that 

would ensure that middle school teachers have demonstrated subject 

matter competency. 

District officials also reported taking steps, such as changing their 

personnel policies, to ensure that more of their teachers meet the 

requirements. For example, officials in two districts told us that they had 

encouraged principals to consider dismissing teachers who were not on 

track to meet the requirements. In another state, districts were reassigning 

teachers to positions for which they met the requirements, and one 

district’s officials instituted a policy of preventing teachers from

transferring to any positions for which they did not meet the requirements. 

Officials in most districts also told us that they have incorporated 

NCLBA’s teacher qualification criteria into their screening of new 

candidates. Further, officials from 6 of the 11 districts that we visited told

 38 See GAO-03-631. 

Page 26 GAO-06-25 Teacher Qualification Requirements
us that they were reducing the number of teachers with emergency

credentials.

The 11 districts that we visited used Title II funds to support professional 

development for teachers, particularly in core academic subjects. Officials 

in the majority of these districts indicated that NCLBA had led to 

improvements in the kinds of professional development they funded with 

Title II funds. Seven of the 11 districts that we visited also continued to 

use the funds for class size reduction efforts. However, district officials 

told us that they have begun shifting emphasis from class size reduction to

initiatives focused on improving teacher qualifications. Most districts that 

we visited considered student achievement needs in identifying 

appropriate uses of Title II funds and targeted the funds to programs 

designed to help teachers address those needs. Few initiatives in these 

districts targeted specific groups of teachers, such as teachers in highpoverty schools. In addition to using Title II, district officials told us they 

used various other funding sources to support their teacher initiatives, 

including other federal, state, and local funds. 

All districts that we visited used Title II funds to provide professional 

development to teachers and focused their efforts on improving the quality

of instruction in core academic subjects such as reading and math. For 

example, one district used Title II funds to provide summer workshops on 

research-based instructional strategies in reading and paid for 

instructional coaches to support classroom teachers throughout the year.

Two districts reported spending Title II funds on math coaches who 

perform tasks such as working with teachers to develop lessons that 

reflected states’ academic standards and assisting them in using students’

test data to identify and address students’ academic needs. In four 

districts, Title II professional development expenditures included the cost 

of instructional materials, and in one district Title II funds paid for 

substitute teachers while regular teachers attended training. 

Visited School 

Districts Most Often 

Used Title II Funds 

for Professional 

Development 

All Visited Districts Used 

Title II Funds for 

Professional Development, 

and Many of Them Used 

These Funds for Class Size 

Reduction 

In addition to spending for professional development in core academic 

subjects, officials in 10 of the 11 districts reported using Title II funds on 

professional development in other areas, such as on general teaching 

strategies and professional development for nonteaching staff. Most of 

these districts used at least some Title II funds for professional 

development that focused on teaching skills and general teaching 

strategies. For example, one district used Title II funds to support a 

program for all teachers during their first 3 years of employment with the 

Page 27 GAO-06-25 Teacher Qualification Requirements
district, including biweekly workshops on classroom management, student 

assessment, and parental involvement. Another district used the funds to 

help teachers understand the instructional needs of gifted and talented 

students and to adjust teaching methods to best address those students’ 

needs. Seven districts also used Title II funds to offer professional 

development for nonteaching staff, such as school administrative 

personnel. For example, one district coordinated with a postsecondary 

institution to train assistant principals on becoming more effective 

educational leaders, while another district used the funds to develop 

guidance counselors and social workers employed in the district’s schools. 

Officials in the majority of the districts that we visited told us that 

NCLBA’s emphasis on student achievement and on strategies supported by 

research had led to improvements in the kinds of professional 

development they funded with Title II funds. Officials said they had 

become much more selective when approving professional development 

providers, looking for those programs that focused on intensive, researchbased instructional strategies. In one district, for example, officials said 

that before NCLBA, providers were often selected on the basis of their 

long-standing relationship with the district, whereas now the district 

approved only those providers whose programs could be substantiated by

research-based evidence of effectiveness. They also indicated that they 

had moved away from onetime workshops and begun to emphasize 

ongoing professional development that provided teachers with 

opportunities to reinforce and apply concepts learned. Furthermore, 

district officials that we interviewed reported greater emphasis on 

professional development opportunities in core academic subjects in 

which NCLBA required students to be assessed. While officials in some 

districts said that they were moving in the direction of higher-quality 

professional development even before NCLBA, several of them indicated 

that the passage of the act added urgency to these efforts. 

Officials in 7 of the 11 districts that we visited told us that they also used 

Title II funds to hire additional teachers to reduce class size. Districts 

focused their class size reduction efforts on specific grades, depending on

their needs and other funding sources available. For example, one district 

visited focused its Title II-funded class size reduction efforts on the eighth 

grade because the state already provided funding for reducing class size in 

other grades. Officials in another district told us they planned to spend 

most of their Title II allocation on class size reduction because class size 

reduction funding from the state was insufficient. While class size 

reduction may contribute to teacher retention and result in a more 

individualized approach to student instruction, it also increases the 

Page 28 GAO-06-25 Teacher Qualification Requirements
number of classrooms that need to be staffed. As a result, districts that are 

already having problems with teacher recruitment may find it difficult to 

find enough teachers who meet NCLBA’s qualification requirements to 

staff these classrooms. For example, one district visited used about onethird of Title II funds for class size reduction, but district officials 

indicated that recruitment difficulties forced them to continue to hire 

teachers who did not meet NCLBA’s qualification requirements. 

Our previous work found that classroom reduction expenditures 

amounted to more than 50 percent of total Title II funds that districts 

spent during 2002-2003 school year,39 a finding consistent with Education’s 

review of districts’ Title II spending during the same time period.40 Officials 

in states that we visited and educational organization representatives that

we interviewed told us that districts continued to spend funds on activities 

developed under the previous program. However, some state officials told

us that they were encouraging districts to expand their traditional uses of 

these funds and to place a greater emphasis on initiatives designed to 

increase teachers’ effectiveness in the classroom. 

In 6 districts that we visited, officials told us that they had begun shifting 

away from class size reduction efforts to placing greater emphasis on 

initiatives for existing teachers. For example, 2 of the districts stopped 

spending Title II funds on class size reduction efforts, and another district 

planned to eliminate class size reduction expenditures in the next school 

year. Officials in 2 other districts told us that while they still funded class 

size reduction efforts, they had reduced the amount of Title II funds they 

spent for this purpose. District officials indicated that they were now 

redirecting funds to support initiatives designed to improve teachers’ 

subject matter knowledge and instructional skills, such as professional 

development. 

In addition to undertaking professional development and class size 

reduction efforts, 6 of the districts that we visited used Title II funds to 

 39 Our survey of a nationally representative sample of school districts during 2002-2003 

school year showed that classroom reduction expenditures accounted for 56 percent of

total Title II funds districts spent. See GAO-03-631. 

40 Education’s survey of a nationally representative sample of school districts showed that

they spent 58 percent of Title II funds on teachers’ salaries to reduce class size during 2002-

2003 school year. See “Improving Teacher Quality in U.S. School Districts; Districts’ Use of

Title II, Part A, Funds in 2002-2003,” Policy and Program Brief, U.S. Department of

Education, February 6, 2004. 

Page 29 GAO-06-25 Teacher Qualification Requirements
support recruitment and retention activities. For example, 2 districts used 

the funds to advertise open teaching positions, as well as to attend 

recruitment events outside of the district to identify qualified candidates. 

Another district used Title II funds to expand its alternative certification 

program, which allowed qualified candidates to teach while they worked 

to meet requirements for certification. Two districts used Title II funds for 

bonuses to attract successful administrators. To promote greater retention

among new teachers, 3 districts used Title II funds for mentoring activities.

For example, 1 of these districts reported using the funds to provide two 

trained mentors for every new teacher. Ten of the 11 districts that we 

visited did not use Title II funds to support programs that offered 

additional pay to teachers based on their performance or other 

qualifications. A few officials cited reasons for not using such programs, 

such as the expense or the difficulties in ensuring that they are 

implemented fairly. 

Six of the districts that we visited reported taking advantage of NCLBA’s 

transferability option, with most of them transferring Title II funds into 

Title V. Under Title V, districts receive funding to support local education 

reform efforts in a broad range of areas, including activities to improve the 

academic achievement of all students and raise teacher effectiveness. For 

example, one district transferred Title II funds into Title V for initiatives 

designed to address students’ academic needs, such as assessing their 

reading skills. Districts officials indicated that they preferred to transfer 

funds into Title V because it afforded them the most flexibility in spending 

the funds. However, one district transferred Title II funds into Title I to 

provide academic services in reading and math to middle school students. 

In addition to participating in activities funded with districts’ own Title II 

allocations, teachers also took part in activities supported through Title II

grants to universities and in state-level Title II initiatives. Three of the four

university-based grantees that we visited focused on providing 

professional development to teachers in math or science. For example, 

one program reviewed offered a 2-week summer math workshop to 

prepare teachers for the subject matter exams that, if passed, could be

used to demonstrate subject matter competency. Another university 

grantee developed a standards-based online math program for middle 

school teachers based on the math questions that students most frequently 

missed on the state’s assessment. While university officials administering 

that program said that it could be used for teachers to earn points toward 

demonstration of subject matter competency under NCLBA, they did not 

know how many participants in the program had not yet met the 

requirements or how many districts allowed teachers to apply their 

Page 30 GAO-06-25 Teacher Qualification Requirements
participation toward earning points through the state’s HOUSSE. 

Additionally, states used a portion of Title II funds retained by state 

departments of education to support professional development for 

teachers in core academic subjects. In two states that we visited, officials 

reported that state Title II initiatives specifically targeted teachers who 

had not met the subject matter competency requirements of NCLBA; these 

initiatives either offered them professional development in core academic 

subjects or reimbursed them for taking college courses in the subjects 

taught. 

Visited Districts 

Considered Student 

Achievement Needs in 

Identifying Uses of Title II 

Funds 

Officials in the districts that we visited said that in deciding what specific 

initiatives should be funded with Title II funds, such as the types of 

professional development programs for teachers, they considered student

achievement needs and targeted the funds to programs designed to help 

teachers address those needs.41 To identify student achievement needs, 

these officials said that their districts examined students’ results on state 

assessments and a school’s progress in meeting annual student proficiency 

goals in core academic subjects, as required under NCLBA.42 The districts 

then targeted their Title II funds to programs for teachers to improve 

instruction in those subjects in which students were lagging behind. For 

example, officials in one district said that because math was an area in 

which schools did not meet annual student proficiency goals, the district’s 

Title II expenditures were targeted to professional development programs 

in math. In another district, the superintendent indicated that his district 

had placed the primary focus of its Title II initiatives on reading in early 

grades because schools in the district had not met reading proficiency 

goals for elementary students in the past. Some districts considered 

student achievement results in combination with other factors to identify 

most appropriate uses of federal funds. For example, officials in one 

district said that they looked at both schools’ student assessment results 

and teacher experience levels when deciding where to place Title IIfunded instructional coaches. 

 41 Two of the 11 districts reported using additional criteria in making Title II funding

decisions. 

42 NCLBA requires states to develop annual measurable objectives for adequate yearly 

progress that schools and districts must meet to ensure that every student becomes

proficient in math and reading/language arts by school year 2013-2014. 

Page 31 GAO-06-25 Teacher Qualification Requirements
Officials in the districts that we visited said that they involved a variety of 

stakeholders, such as teachers and parents, to help them identify district 

needs that could be addressed with Title II funds. The nature of

stakeholder involvement varied across the districts that we visited. For 

example, several districts administered a survey to teachers, parents, and

students, asking them about their perceptions of the district and its needs. 

Another district administered an online professional development survey 

to its teachers, asking them to assess the type of professional development 

activities received. District officials said they used the results of these 

surveys to decide how to best spend Title II funds. In other districts, 

officials considered stakeholders’ perspectives in less structured ways. 

For example, in one district that did not have a separate process for 

gathering stakeholders’ views prior to making funding decisions, officials 

said that stakeholders’ perspectives were still considered as the result of 

the superintendent’s regular meetings with school officials and parent 

groups across the district. 

While most districts that we visited targeted Title II funds to subject areas 

that presented academic challenges to students, only a few of the Title II 

funded initiatives were directed to specific groups of teachers, such as 

teachers in high-poverty schools or teachers who had not yet met the 

requirements of NCLBA. One district that we visited targeted Title II 

dollars to teachers in high-poverty schools, funding initiatives such as 

reimbursing these teachers for taking college classes necessary for them 

to meet state certification requirements and providing tuition for teachers 

in alternative certification programs who agreed to teach in high-poverty 

schools. In four districts that we visited, officials reported having 

initiatives specifically for teachers who had not yet met NCLBA’s 

qualification requirements. Some of these initiatives offered 

reimbursement to teachers for taking college courses or other professional 

development that they could use to demonstrate compliance with 

NCLBA’s requirements. Other initiatives helped teachers prepare for 

subject matter exams and reimbursed the registration fees of those who 

passed them to demonstrate subject matter competency in the subject 

taught. While many professional development programs supported with 

Title II funds were not necessarily targeted to teachers who still needed to 

meet the requirements, teachers who had not met the requirements could 

count their participation toward demonstration of subject matter 

competency under NCLBA by earning points through their state’s 

HOUSSE. 

In each of the districts that we visited, any teacher could participate in at 

least some professional development or other programs supported with 

Page 32 GAO-06-25 Teacher Qualification Requirements
Title II funds, and district officials indicated that they had made efforts to

address district-wide teacher needs. Ten of the 11 districts that we visited

had a large number of high-poverty schools,43 and by focusing on 

districtwide teacher needs, district officials could also address the needs 

of teachers who provided instruction to low-income students. For 

example, the superintendent of 1 district, in which all teachers could 

participate in Title II initiatives, credited the professional development 

funded through Title II with the narrowing of the achievement gap 

between the district’s low-income and other students. The statutory 

formula that states used to allocate Title II funds to the districts takes into 

consideration their poverty levels,44 and several officials we interviewed 

told us they believed Title II funds were generally reaching districts with 

the greatest need. 

Visited Districts Used NonTitle II Funds to Support 

Teacher Initiatives

Title II funds are generally a small part of total funds available to the 

districts for teacher initiatives, and visited districts used various non-Title 

II funds to address their teacher needs, including other federal, state, and

local funds. In two districts, for example, officials told us that Title II funds 

represented less than half of all the funds they spent on teacher initiatives. 

Moreover, districts received federal funds under different programs, and 

Title II constitutes a relatively small proportion of all federal funds they 

could use for teacher initiatives. In one district visited, for example, Title II 

funds constituted about 13 percent of the total federal funds available, 

with the bulk of the district’s federal money coming from Title I. Our prior 

work also showed that districts planned to spend much larger percentages 

of other federal, state, and local funds than Title II funds on teacherrelated activities, but in high-poverty districts Title II funds constituted a 

larger share of total funds spent on these activities than in low-poverty 

districts.45

 43 We visited one district that did not have high-poverty schools but was chosen because of

its rural location. 

44 After awarding to each district the amount of Title II funds equivalent to what the district 

received in fiscal year 2001 under the Eisenhower Professional Development and Class-Size 

Reduction programs, the state allocates any excess funds to the districts based on the

following formula: 20 percent of the excess funds must be distributed based on the 

district’s relative number of individuals ages 5 through 17 residing in the area served by the 

district; 80 percent of the excess funds must be distributed based on the relative number of

individuals ages 5 through 17 residing in the area served by the district who are also from 

families with incomes below the poverty line. 

45 See GAO-03-631. 

Page 33 GAO-06-25 Teacher Qualification Requirements
Although Title II was one of many resources available to the districts, 

many district officials we interviewed said that Title II funds played a 

significant role in their teacher improvement efforts. For example, officials 

in one district credited Title II-funded professional development with 

helping teachers prepare for subject matter tests they needed to pass in 

order to demonstrate subject matter competency under NCLBA. In 

another district, officials said that their initiatives to support teachers, 

such as coaches, would not have been possible without Title II funding. 

Districts that we visited supported a variety of teacher programs with nonTitle II funds. Among other federal funds, Title I was one of the most 

frequently cited sources for supporting teacher initiatives. For example, 

two districts used Title I funds to hire coaches or consultants to help 

individual teachers in high-poverty schools become more effective in the 

classroom. A few of the initiatives funded with Title I were specifically

designed to help teachers meet NCLBA’s qualification requirements. For 

example, one district used the funds to reimburse teachers who passed the 

subject matter exam for their registration fees and for taking additional 

college coursework to help them meet NCLBA’s subject matter 

competency requirements. In addition to using federal funds, districts also 

used state funds for teacher initiatives. For example, districts in one state 

received funds from the state for activities such as professional 

development to support all beginning teachers. Finally, districts used local 

and private funds to support various teacher initiatives. For example, one 

district used local funds to reimburse teachers for taking additional 

courses to raise their qualifications, while another district used private

foundation funds to provide housing allowances for high-performing 

teachers who accepted positions in the district’s most struggling inner-city

schools. 

Two districts that we visited had implemented or planned to implement 

differential compensation programs that offered financial rewards to 

teachers, such as onetime bonuses or salary increases, based on their 

performance or other qualifications. One school district in Tennessee 

made recruitment, retention, and salary bonuses available to teachers who 

had demonstrated a record of effectiveness and taught in some of the 

district’s neediest schools.46 To assess teachers’ eligibility for these 

 46 Hamilton County Schools is an urban school district in Chattanooga, Tennessee, with 79 

schools, 2,674 full-time teachers, and student enrollment of 40,494 in the 2004-2005 school 

year. 

Page 34 GAO-06-25 Teacher Qualification Requirements
bonuses, the district used the data showing teachers’ impact on student 

performance available through the state’s system of measuring students’ 

achievement gains from year to year. This initiative is currently supported 

with both Title I and Title II funds. A school district in Colorado approved

a plan for a districtwide differential compensation system that would 

provide teachers with multiple opportunities to increase their yearly pay,

including gaining additional knowledge and skills, assuming positions in 

hard-to-fill subjects or hard-to-staff schools, earning successful 

performance evaluations, or meeting annual objectives for students’ 

performance.47 This initiative will be funded through a local property tax 

increase that will create a trust fund to ensure that the new pay system can 

be permanently sustained.48 While officials in that district acknowledged 

that Title II funds could be used to support differential compensation 

initiatives, they indicated that Title II alone could not sustain this system. 

Officials in the districts that we visited said that they did not look at Title 

II funds in isolation from other funds when making funding decisions, but 

rather they attempted to leverage different funding sources available to

address their teacher needs. For example, officials in one district said that

the district’s use of Title I funds for teacher recruitment purposes allowed 

them to focus Title II funds on the coaching program for teachers. 

 47 Denver Public Schools is an urban school district in Denver, Colorado, with 154 schools,

4,061 teachers, and student enrollment of 72,901 in the 2004-2005 school year. 

48 In November 2005, Denver voters approved a property tax increase that will be used to

finance the differential compensation system. Beginning on January 1, 2006, all new

teachers will be automatically enrolled in the new system; current teachers will be able to

opt into the system over the first 7 years or remain in the current system. 

Page 35 GAO-06-25 Teacher Qualification Requirements
Education monitored states and offered assistance to help teachers meet

NCLBA’s teacher qualification requirements. In its monitoring reports, 

Education identified areas of concern related to states’ implementation of 

the teacher qualification requirements. Education’s assistance efforts 

included professional development opportunities and information packets

on NCLBA’s requirements. The agency also conducted site visits to states 

to discuss NCLBA’s teacher qualification requirements and offer technical

assistance. Although several key resources about NCLBA’s teacher 

requirements can be reached only through Education’s Web site, officials

in most states and districts that we visited told us that they had difficulty

locating these resources or were unaware of them. Our review of 

Education’s Web site showed that several key resources on NCLBA’s 

teacher qualification requirements were located on different Web pages 

that were not linked, making it challenging to find them. 

Education provided written feedback to states on their implementation of 

NCLBA’s teacher qualification requirements through the Title II 

monitoring process. Education began Title II monitoring in June 2004 and, 

as of July 15, 2005, had conducted monitoring visits to 29 states and the 

District of Columbia and released reports documenting findings to 20 of 

the states. Reports were generally released to states about 1 to 3 months 

after the monitoring visit. Education officials reported that states had an

opportunity to respond prior to the release of monitoring reports, and to 

develop a plan to address findings. None of our site visit states received a 

monitoring report in time to be included in this analysis. 

Education Monitored 

States and Offered 

Assistance on 

Implementing the 

Requirements, but 

Some of Education’s 

Information Was Not 

Readily Accessible 

Education Monitored 

States’ Implementation of 

Teacher Qualification 

Requirements 

In these 20 monitoring reports, Education issued findings to states that did 

not fully implement NCLBA requirements. States most frequently received 

findings for not ensuring that teachers hired into Title I schools or with 

Title II funds met the teacher requirements (14 states), as required by 

NCLBA. Another frequent finding was that state-reported data did not 

adequately reflect the status of teachers in meeting the requirements (13 

states). For example, several states could not report data on the 

percentage of classes taught by teachers not meeting NCLBA’s teacher 

qualification requirements for special education or secondary school 

classes. 

In addition, some states received findings for not requiring certain 

teachers to demonstrate subject matter competency as required under 

NCLBA. For example, 9 states received findings for allowing teachers of 

history, geography, civics/government, or economics to demonstrate 

subject matter competency in the broad area of social studies instead of in

Page 36 GAO-06-25 Teacher Qualification Requirements
each subject taught. Seven states received findings for not requiring new 

elementary school teachers to demonstrate competency in the manner 

required by NCLBA. Education found that all 7 states had not implemented 

a test for new elementary school teachers to demonstrate subject matter 

competency or the test was optional. Eight states received findings related 

to the demonstration of competency for middle and high school teachers, 

and 7 states received findings related to the demonstration of competency

for special education teachers. In states that did not require certain 

teachers to demonstrate competency as required by NCLBA, state data do

not fully reflect the percentage of classes taught by teachers who met 

NCLBA teacher qualification requirements. 

Table 1 lists the major findings related to NCLBA’s teacher qualification

requirements. 

Page 37 GAO-06-25 Teacher Qualification Requirements
Table 1: Major Findings from Education’s Title II Monitoring 

Teacher qualification requirements that states did not fully 

implement 

Number

 of states

 with finding

Hiring 

Did not ensure that teachers hired into Title I schools or with Title II 

funds met the requirements 14

Reporting and data

Did not include all required data elements on state report card 10

State-reported data did not adequately reflect the status of teachers 

in meeting the requirements 13

Demonstration of subject matter competency 

Did not require a state test for new elementary teachers to 

demonstrate subject matter competency 8

Requirements for veteran elementary teachers were not sufficient to 

demonstrate subject matter competency 5

Requirements for middle or high school teachers were not sufficient 

to demonstrate subject matter competency 8

Did not require teachers of history, geography, civics/government, or 

economics to demonstrate subject matter competency in each 

subject taught 9

Did not require special education teachers to demonstrate subject 

matter competency in subjects taught or have not determined the 

status of these teachers 7

State HOUSSE procedures did not meet criteria in the law 1

Development of annual measurable objectives and plan for meeting the 

requirements

Did not develop annual measurable objectives for districts and 

schools 12

Source: GAO analysis of Education’s Title II monitoring reports. 

Note: Information presented for 20 monitoring reports reviewed by GAO. 

Of the 20 states that received monitoring reports, 19 states did not receive

a finding regarding their HOUSSE procedures, even though some experts 

have questioned the rigor of HOUSSE procedures in many states. Through 

the monitoring process, Education is reviewing state HOUSSE procedures 

to ensure that they are consistent with NCLBA’s criteria. Table 2 lists 

NCLBA’s criteria for state HOUSSE procedures. 

Page 38 GAO-06-25 Teacher Qualification Requirements
Table 2: NCLBA’s Criteria for HOUSSE Procedures 

States can establish a process for evaluating teacher knowledge and ability based 

on the standard that meets the following criteria: 

Is set by the state for both grade-appropriate academic subject matter knowledge and 

teaching skills 

Is aligned with challenging state academic content and student academic achievement 

standards and developed in consultation with core content specialists, teachers, 

principals, and school administrators 

Provides objective, coherent information about the teacher’s attainment of core content 

knowledge in the academic subjects taught 

Is applied uniformly to all teachers in the same academic subject and the same grade 

level throughout the state 

Takes into consideration, but not be based primarily on, the time the teacher has been 

teaching in the academic subject 

Is made available to the public upon request

May involve multiple objective measures of teacher competency 

Source: NCLBA, Pub.L. No. 107-110, section 9101(23)(C)(ii). 

As long as their HOUSSE procedures meet each of NCLBA’s criteria, states 

have had flexibility in developing HOUSSE under NCLBA. Among 19 states 

with HOUSSE procedures that were determined to meet NCLBA’s criteria 

were one state with a HOUSSE that allowed for evaluations of teachers’ 

classroom performance and several states in which teachers meet 

HOUSSE requirements by being fully certified to teach their subject. 

Education officials noted that evaluations of teachers’ performance could 

be accepted as part of state HOUSSSE procedures as long as they are 

rigorous and objective measures of teachers’ subject matter knowledge 

that are based on multiple observations and performed by trained 

evaluators. In addition, Education officials told us that while teacher 

certification in itself would not be sufficient for demonstration of subject 

matter competency, several states provided evidence that was accepted by

Education showing that their certification requirements met the criteria 

for HOUSSE in the law. In the one state that received a finding related to

its HOUSSE, teachers were allowed to earn more than half of the points 

necessary to meet HOUSSE requirements through experience. The state 

received a finding because NCLBA does not allow HOUSSE to be based 

primarily on teaching experience. 

Eleven of the 20 state monitoring reports included written commendations 

from Education for state efforts to improve professional development, 

strengthen teacher preparation, or develop data systems that track teacher 

qualifications. Eight states received commendation for improving or 

Page 39 GAO-06-25 Teacher Qualification Requirements
offering high-quality professional development for teachers. For example, 

Arkansas was commended for requiring every teacher to complete 60

hours of professional development each year and devoting considerable 

state funding to professional development. Seven states were commended 

for strengthening teacher preparation. For example, Georgia was 

commended for aligning all teacher preparation to state standards for 

student learning. Six states were commended for new or improved data 

systems for tracking teacher qualifications. For example, Mississippi 

received a commendation for tracking teachers’ qualifications, 

certifications, and assignments, and linking those factors to individual 

students’ progress. 

Education Offered 

Assistance to Teachers and 

States on the 

Implementation of Teacher 

Qualification 

Requirements 

Education offered several types of assistance to help the nation’s 3 million 

public school teachers meet NCLBA’s teacher qualification requirements, 

including professional development opportunities. Education offered 

professional development opportunities workshops in which about 4,500 

teachers have participated since June 2004. These workshops and related

materials were also made available online free of charge. Teachers 

accessed these workshops online through Education’s Web site or through

www.teacherquality.us, a Web site Education uses to provide information 

on Education’s teacher initiatives. In addition, teachers can determine 

whether their state would accept these workshops as credit toward the 

state HOUSSE requirement online. As of September 2005, all states and the 

District of Columbia were awarding points for teachers’ participation in 

these workshops as part of their HOUSSE procedures or for teacher 

recertification. 

Education also offered assistance directly to teachers to help them 

understand NCLBA’s requirements and gave teachers an opportunity to 

provide feedback about what additional support they need. Education 

distributed 255,000 “Toolkit for Teachers” information packets that 

provide information about NCLBA’s teacher qualification requirements. 

The toolkit addressed frequently asked questions that are relevant to 

teachers, such as whether NCLBA’s teacher qualification requirements 

apply to special education teachers. In addition, Education offered a series 

of teacher roundtables that gave teachers an opportunity to share their 

views with Education officials on how Education can support them in the 

classroom. 

Education provided technical assistance to state officials from all 50 states 

through site visits by the Teacher Assistance Corps (TAC). TAC visits, 

which took place prior to Education’s monitoring of NCLBA’s teacher 

Page 40 GAO-06-25 Teacher Qualification Requirements
qualification requirements, were intended to help states implement the 

requirements, according to Education officials. The TAC teams that 

conducted site visits were composed of Education officials and experts. 

Education characterized these visits as “conversations without 

consequences” and did not provide written feedback to states based on the 

TAC visits. Education officials said that TAC teams discussed HOUSSE 

procedures, the collection of data on teacher qualifications, the best use of

Title II funds, and other issues. Officials from two of the six states that we 

visited said that TAC suggestions helped them implement their HOUSSE 

procedures. Three other states that we visited said that TAC teams’ 

suggestions were not useful in their circumstances. For example, officials 

in one state said that Education’s suggestion that small rural districts 

share teachers to ensure that students are taught by teachers who meet 

NCLBA’s requirements was impractical given the distance between 

schools. Based on difficulties that states identified during TAC visits, 

Education offered science teachers and teachers of multiple subjects, 

including rural teachers, additional flexibility in meeting NCLBA’s teacher 

requirements. 

Through TAC visits, Education officials identified state and local 

initiatives that they considered to be innovative ways of improving teacher

qualifications. Such initiatives addressed teacher certification and 

licensing, professional development, and other topics. In an effort to share 

information on these state and local initiatives with policy makers or 

others, Education posted information about these initiatives on

www.teacherquality.us. 

Education has provided guidance and hosted meetings for state officials 

on the implementation of NCLBA’s teacher qualification requirements. 

Education’s guidance answered questions about NCLBA’s teacher 

qualification requirements and Title II, such as when teachers with 

alternative certification can be considered as having met NCLBA’s teacher

requirements. Education officials reported that they update their guidance 

periodically to answer new questions about the teacher requirements, 

most recently in August 2005. In addition, Education convenes state Title 

II directors once a year to provide updates on the implementation of 

NCLBA’s teacher requirements. 

Education has also funded several projects that work to improve the 

preparation and increase the numbers of special education teachers. For 

example, one center compared special education teachers prepared in 

alternative certification programs with their counterparts from traditional 

preparation programs. 

Page 41 GAO-06-25 Teacher Qualification Requirements
According to Education officials, Education’s Web site has been an 

important part of their outreach efforts regarding NCLBA’s teacher 

qualification requirements. Several of the resources related to

implementation of the teacher qualification requirements, such as the 

Teacher Toolkit and state innovative practices, are now available only 

through Education’s Web site. However, officials from most states and 

districts that we visited who use Education’s Web site to access 

information on teacher programs or requirements told us that they were 

unaware of some of Education’s teacher resources or had difficulty 

accessing those resources. For example, although all of the states we 

visited accepted Education’s professional development for credit toward 

recertification or HOUSSE, district officials from only 3 of the 11 districts 

we spoke with were aware of these opportunities or that they were 

available online. Moreover, officials in 4 of the states that we visited told 

us that they wanted to know more about other states’ initiatives to 

improve teacher qualifications but were not aware that Education had 

made this information available online or did not know how to access the 

information. In the states that we visited, several state and local officials 

mentioned that they attempted to find information by using Education’s 

search function but often had trouble finding what they needed. 

Some Information on 

Education’s Web Site Was 

Not Readily Accessible 

In our review of Education’s Web site, we found that information and 

resources on the teacher qualification requirements were located on 

several different Web pages that sometimes were not linked, making the 

information difficult to locate. For example, state initiatives were available 

through the “Teachers” section of Education’s Web site and not through 

the “Administrators” section, even though state and local administrators 

would likely find this information more useful than teachers would. See 

figure 4 for the description of teacher qualification information included 

on different sections of Education’s Web site. 

Page 42 GAO-06-25 Teacher Qualification Requirements
Figure 4: Information on Teacher Qualifications Available through Education’s Web Site, as of August 2005 

Source: GAO analysis of Education’s data.

Policy documents related 

to NCLBA:

Guidance on teacher qualification 

requirements

Information for administrators:

Professional development

Guidance on teacher qualification 

requirements

No direct link to state and local

teacher initiatives

Information for NCLBA:

Professional development

Guidance on teacher qualification requirements

Examples of state and local 

teacher initiatives

Information for teachers:

Examples of state and local 

teacher initiatives

Professional development

www.ed.gov

Since we last reported on the status of implementing the teacher 

qualification requirements in our 2003 report, state and district officials 

have taken steps to implement these requirements, such as reducing the

number of uncertified teachers and developing data systems to track 

teachers’ qualifications. In addition, Education officials indicated that 

states have taken steps to raise teacher qualifications through changes in

state certification systems. 

Conclusions 

Although states have made progress in tracking teacher qualifications data

and reporting on their status in meeting the requirements, difficulties 

remain in identifying teachers who do not meet the requirements. This 

may be a challenge, particularly because a number of states did not 

include all teachers in their calculations or faced other data issues. Where 

data challenges exist, Education and the states may not have the 

information necessary to direct assistance to where it is most needed. This 

Page 43 GAO-06-25 Teacher Qualification Requirements
may result in some teachers not receiving appropriate support to help 

them meet the requirements. Education is working on identifying data

challenges and addressing them through its monitoring visits and other 

technical assistance to states. Until these data issues are resolved, state 

reports on their status in meeting the teacher qualification requirements 

should be viewed as preliminary. 

To facilitate state and district implementation efforts, Education relies 

extensively on its Web site as one of its principal means for providing 

information and implementation resources for states and districts. 

However, state and district officials told us that they were unaware of 

some of the information resources that Education made available and had

difficulty locating other known sources of information on Education’s Web 

site. Consequently, states and districts may not be taking full advantage of

the opportunities and flexibilities made available by Education that would 

help them meet teacher qualification goals. Further, without this 

information, some states and districts may not be correctly applying the

requirements, thus jeopardizing the ability of their teachers to meet the 

requirements by the deadline. This may impede efforts to increase student 

performance and ensure that all students reach state standards. 

Finally, even when all teachers have met NCLBA’s qualification 

requirements, it is unclear whether their doing so will have the expected 

effect on student performance. Under the law, states have considerable 

flexibility in developing requirements for teachers to demonstrate subject 

matter competency. The rigor of these requirements varied across states. 

Consequently, it remains to be seen how different state requirements will 

affect the quality of instruction and student performance. 

We recommend that the Secretary of Education explore ways to make the 

Web-based information on teacher qualification requirements more 

accessible to users of its Web site. Specifically, the Secretary may want to 

more prominently display the link to state teacher initiatives, as well as 

consider enhancing the capability of the search function. 

We provided a draft of this report to Education for review and comment. 

In its letter, Education agreed with our recommendation, indicating that 

the department has already taken steps to address it. Specifically, the 

department is reviewing how teacher qualification information on the 

“Teachers” section of its Web site can be better integrated with related 

Recommendation for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 44 GAO-06-25 Teacher Qualification Requirements
information on other Web sites, including teacherquality.us. Education’s 

written comments are reproduced in appendix IV. 

We are sending copies of this report to the Secretary of Education, 

relevant congressional committees, and other interested parties. We will 

also make copies available to others upon request. In addition, the report

will be made available at no charge on GAO’s Web site at 

http://www.gao.gov. 

Please contact me at (202) 512-7215 if you or your staff have any questions 

about this report. Other contacts and major contributors are listed in 

appendix V.

Marnie S. Shaul, Director

Education, Workforce, and 

 Income Security Issues 

Page 45 GAO-06-25 Teacher Qualification Requirements
Appendix I: Activities on Which States and Appendix I: Activities on Which States and Districts Can Spend Title II, Part A, Funds 

Districts Can Spend Title II, Part A, Funds 

Table 3 lists our summaries of the authorized activities on which states 

can spend Title II funds and shows the five categories we used to group 

them. After reserving 1 percent of the total Title II allocation to the state 

for administrative activities, states retain only 2.5 percent of the remaining 

99 percent for state activities. 

Table 3: Title II, Part A, State Activities 

Category Activity

1. Developing systems to measure the effectiveness of professional development programs and strategies 

to document improvements in students’ academic achievement 

Accountability 

2. Ensuring that teachers use challenging state academic content standards, assessments, and student 

achievement standards to improve their teaching practices and their student’s achievement 

3. Reforming teacher and principal certification 

4. Reforming tenure and implementing tests for subject matter knowledge 

5. Promoting license and certification reciprocity agreements with other states for teachers and principals 

Certification 

6. Providing programs that establish, expand, or improve alternative routes for state certification, 

especially for highly qualified individuals in the areas of mathematics and science 

7. Conducting programs that provide support to teachers, such as those that provide teacher mentoring 

and use assessments that are consistent with student academic achievement standards

8. Providing professional development for teachers and principals 

9. Developing or assisting local educational agencies (LEAs) in developing and using proven innovative 

strategies for intensive professional development programs that are both cost-effective and easily 

accessible 

10. Encouraging and supporting the training of teachers and administrators to integrate technology into 

curricula and instruction, including training to improve their ability to use data to improve their teaching 

Professional 

development 

11. Providing assistance to teachers to enable them to meet certification, licensing, or other Title II 

requirements needed to become highly qualified 

12. Developing or assisting LEAs to develop, merit-based performance systems and strategies that provide

pay differentials and bonus pay for teachers in academic subjects in which there is high need 

13. Developing projects and programs to encourage men to become elementary teachers 

14. Establishing and operating a statewide clearinghouse and programs for the recruitment, placement, and 

retention of teachers 

15. Assisting LEAs and schools in recruiting and retaining highly qualified teachers, including specialists in 

core subjects 

Recruitment and 

retention 

16. Developing or assisting LEAs to develop teacher advancement initiatives that promote professional 

growth and emphasize multiple career paths and pay differentiation 

17. Fulfilling the state agency’s responsibility to properly and efficiently carry out the administration of 

programs, including providing technical assistance to LEAs 

Technical assistance 

18. Assisting LEAs to develop and implement professional development programs and school leadership 

academies for principals and superintendents 

Source: NCLBA Pub.L. No. 107-110, section 2113. 

Page 46 GAO-06-25 Teacher Qualification Requirements
Appendix I: Activities on Which States and 

Districts Can Spend Title II, Part A, Funds 

Table 4 lists our summaries of the authorized activities on which districts 

can spend Title II funds and shows the two categories we used to group 

them. After reserving 1 percent of the total Title II allocation to the state 

for administrative activities, states allocate 95 percent of the remaining 99

percent to the districts. 

Table 4: Title II, Part A, District Activities 

Category Activity 

1. Providing professional development activities for teachers and principals that improve their 

knowledge of their core subjects and effective instructional strategies 

2. Carrying out professional development activities designed to improve the quality of principals and 

superintendents 

3. Carrying out teacher advancement initiatives to promote professional growth and to emphasize 

multiple career paths and pay differentiation

Professional development 

4. Carrying out programs and activities that are designed to improve the quality of teachers, such as 

professional development programs, merit pay programs, and testing teachers in the subjects 

they teach 

5. Developing and implementing mechanisms to assist schools in effectively recruiting and retaining 

highly qualified teachers and principals 

6. Developing and implementing initiatives to retain highly qualified teachers and principals, 

particularly in schools with a high percentage of low-achieving students, including programs that 

provide teacher mentoring and incentives 

7. Carrying out programs and activities related to exemplary teachers 

8. Developing and implementing initiatives to assist schools in recruiting and hiring teachers, 

including providing financial incentives and establishing programs that train and hire special 

education and other teachers, recruit qualified professionals from other fields, and provide 

increased opportunities for minorities, individuals with disabilities, and others 

Recruitment and retention 

9. Hiring highly qualified teachers in order to reduce class size, particularly in the early grades 

Source: NCLBA Pub.L. No. 107-110, section 2123. 

Page 47 GAO-06-25 Teacher Qualification Requirements
Appendix II: State-Reported Percentage of 

Core Academic Classes Taught by Teachers 

Meeting NCLBA’s Teacher Qualification 

Requirements in the 2003-2004 School Year 

States 

All 

 schools

High-poverty

 schools

Low-poverty

 schools

Elementary

 schools

Secondary

 schools

Alabama 77 68 79 80 77

Alaska np np np np np

Arizona 96 96 96 98 94

Arkansas np np np np np

California 52 40 60 49 53

Colorado 91 90 92 95 86

Connecticut 99 98 99 99 99

Delaware 73 68 74 74 72

District of Columbia np np np np np

Florida 89 87 91 94 85

Georgia 97 97 98 98 95

Hawaii 73 71 73 90 68

Idaho 97 98 96 98 97

Illinois 98 93 100 np np

Indiana 96 94 97 96 97

Iowa 95 96 95 97 94

Kansas 95 96 95 98 93

Kentucky 95 98 95 99 92

Louisiana 90 87 92 95 86

Maine 90 91 91 93 89

Maryland 67 47 78 73 64

Massachusetts 94 88 96 95 92

Michigan 92 92 93 97 89

Minnesota 99 98 99 99 98

Mississippia93 89 95 97 91

Missouri 96 92 97 np np

Montana 99 98 99 99 98

Nebraska 91 90 95 98 90

Nevada 64 59 75 71 51

New Hampshire 73 69 73 76 70

New Jersey 94 88 96 94 95

New Mexico 67 63 72 74 65

New York 92 81 97 92 94

North Carolina 85 82 87 88 82

North Dakota 77 83 73 100 56

Appendix II: State-Reported Percentage of 

Core Academic Classes Taught by Teachers 

Meeting NCLBA’s Teacher Qualification 

Requirements in the 2003-2004 School Year 

Page 48 GAO-06-25 Teacher Qualification Requirements
Appendix II: State-Reported Percentage of 

Core Academic Classes Taught by Teachers 

Meeting NCLBA’s Teacher Qualification 

Requirements in the 2003-2004 School Year 

States 

All 

 schools

High-poverty

 schools

Low-poverty

 schools

Elementary

 schools

Secondary

 schools

Ohio 93 91 95 93 93

Oklahoma 98 97 98 98 98

Oregon 87 85 89 97 85

Pennsylvania 97 92 99 np np

Puerto Rico np np np np np

Rhode Island 76 77 74 75 75

South Carolina 75 68 79 75 75

South Dakota 93 89 93 94 91

Tennessee 58 57 50 60 51

Texas 92 92 93 97 93

Utah 69 65 73 80 70

Vermont np np np np np

Virginia 95 92 97 96 94

Washington 99 99 99 100 99

West Virginia 96 97 95 97 95

Wisconsin 98 96 99 99 98

Wyoming 99 99 99 100 98

Source: U.S. Department of Education, State Consolidated Performance Reports. 

Notes: We identified several factors that affect the accuracy of these data and preclude a comparison 

of classes taught by teachers meeting the requirements across states. However, on the basis of our 

work, we determined state-reported percentages could be used to demonstrate how close a particular 

state was to reaching the goal of having all its teachers meet the requirements. All numbers have

been rounded to the nearest whole figure. 

a

These data exclude classes that have students from both elementary and secondary grades. 

Np = data were not provided by the states. 

Page 49 GAO-06-25 Teacher Qualification Requirements
Appendix III: Sample HOUSSE Procedures Appendix III: Sample HOUSSE Procedures from Two States Visited 

from Two States Visited 

Page 50 GAO-06-25 Teacher Qualification Requirements
Appendix III: Sample HOUSSE Procedures 

from Two States Visited 

Page 51 GAO-06-25 Teacher Qualification Requirements
Appendix III: Sample HOUSSE Procedures 

from Two States Visited 

Page 52 GAO-06-25 Teacher Qualification Requirements
Appendix IV: Comments from the U.S. Appendix IV Department of Education : Comments from the U.S. 

Department of Education 

Page 53 GAO-06-25 Teacher Qualification Requirements
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 54 GAO-06-25 

Appendix V: GAO Contact and Staff 

Acknowledgments 

Marnie S. Shaul, (202)512-7215, shaulm@gao.gov

Harriet Ganson (Assistant Director) and Natalya Barden (Analyst-inCharge) managed all aspects of the assignment. Scott Spicer, Katharine 

Leavitt, and Deborah Edwards made significant contributions to this 

report. Other key contributors to this report included Jessica Botsford, 

Richard Burkard, Emily Leventhal, Jonathan McMurray, Jean McSween, 

John Mingus, and Shannon VanCleave. 

GAO Contact 

Staff 

Acknowledgments 

 Teacher Qualification Requirements
Related GAO Products Related GAO Products 

No Child Left Behind Act: Education Could Do More to Help States Better 

Define Graduation Rates and Improve Knowledge about Intervention 

Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005. 

No Child Left Behind Act: Most Students with Disabilities Participated 

in Statewide Assessments, but Inclusion Options Could Be Improved. 

GAO-05-618. Washington, D.C.: July 20, 2005. 

Charter Schools: To Enhance Education’s Monitoring and Research, 

More Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.: 

Jan. 12, 2005.

No Child Left Behind Act: Education Needs to Provide Additional 

Technical Assistance and Conduct Implementation Studies for School 

Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004.

No Child Left Behind Act: Improvements Needed in Education’s Process 

for Tracking States’ Implementation of Key Provisions. GAO-04-734. 

Washington, D.C.: Sept. 30, 2004. 

No Child Left Behind Act: Additional Assistance and Research on 

Effective Strategies Would Help Small Rural Districts. GAO-04-909. 

Washington, D.C.: Sept. 23, 2004. 

Special Education: Additional Assistance and Better Coordination 

Needed among Education Offices to Help States Meet the NCLBA Teacher 

Requirements. GAO-04-659. Washington, D.C.: July 15, 2004. 

Student Mentoring Programs: Education’s Monitoring and Information 

Sharing Could Be Improved. GAO-04-581. Washington, D.C.: June 25, 

2004. 

No Child Left Behind: More Information Would Help States Determine 

Which Teachers Are Highly Qualified. GAO-03-631. Washington, D.C.: 

July 17, 2003.

Title I Characteristics of Tests Will Influence Expenses; Information 

Sharing May Help States Realize Efficiencies. GAO-03-389. 

Washington, D.C.: May 8, 2003. 

(130434) Page 55 GAO-06-25 Teacher Qualification Requirements
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